Shareda Hope Rawls v. the State of Texas, 04-22-00709-CR

Shareda Hope Rawls, a staff member at a juvenile facility, was convicted of sexually assaulting H.S., a 16-year-old resident.
Rawls admitted to having sex with H.S. but claimed it was not assault because H.S. raped her.
The jury found Rawls guilty and recommended community supervision; the trial court entered judgment accordingly.
Rawls filed a motion for a new trial, which was denied, and then appealed.
On appeal, Rawls argued (1) ineffective assistance of counsel regarding a motion to suppress, and (2) violation of her confrontation rights by not being allowed to impeach H.S. with his juvenile record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective Assistance of Counsel	Trial counsel inadequately prepared for the motion to suppress, not raising all issues	Counsel's reasons not explained, actions may be strategy	Record insufficient to show deficient performance under Strickland
Right to Confront Witness (Confrontation Clause)	Not allowed to impeach H.S.'s credibility with juvenile record evidence	Issue not preserved for appellate review	Issue not preserved, pre-trial in limine ruling does not suffice

Strickland v. Washington, 466 U.S. 668 (1984) (sets two-prong test for ineffective assistance of counsel)
Thompson v. State, 9 S.W.3d 808 (Tex. Crim. App. 1999) (ineffective assistance requires defendant to overcome presumption of reasonable strategy)
Lopez v. State, 343 S.W.3d 137 (Tex. Crim. App. 2011) (ineffective assistance claims rarely succeed on direct appeal)
Goospeed v. State, 187 S.W.3d 390 (Tex. Crim. App. 2005) (deficient performance not found unless conduct is outrageous)
Warner v. State, 969 S.W.2d 1 (Tex. Crim. App. 1998) (pre-trial limine motions do not preserve error; must offer evidence at trial)
Paredes v. State, 129 S.W.3d 530 (Tex. Crim. App. 2004) (Confrontation Clause objections must be preserved at trial)