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The Texas law of parties[1] states that a person can be criminally responsible for the actions of another in certain circumstances, including "[i]f in the attempt to carry out a conspiracy to commit one felony, another felony is committed by one of the conspirators, all conspirators are guilty of the felony actually committed, though having no intent to commit it, if the offense was committed in furtherance of the unlawful purpose and was one that should have been anticipated as a result of the carrying out of the conspiracy."

In Texas capital cases, a person convicted under the law of parties may not be sentenced to death if convicted under the law of parties unless the sentencing jury finds beyond a reasonable doubt that "the defendant actually caused the death of the deceased or did not actually cause the death of the deceased but intended to kill the deceased or another or anticipated that a human life would be taken."[2]

In 2021 and 2023, the Texas House of Representatives voted in favor of bills intended to limit death penalty eligibility under the law of parties, but neither of the bills advanced to the next stage.[3][4]

Convictions under the law

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People sentenced to death under the law include Carlos Santana,[5] Carlos Trevino,[6] Cleve Foster,[7] Clinton Young,[8] Donald Newbury,[9] Doyle Skillern,[10] George Rivas,[11] G.W. Green,[12] Humberto Garza,[13] Jeffery Wood, Jessie Gutierrez,[14] John Adams,[15] Joseph Garcia,[16] Joseph Nichols,[17][18] Juan Ramirez,[19] Kenneth Foster, Michael Rodriguez,[20] Miguel Martinez,[21] Patrick Murphy, Randy Halprin, Ray Jasper,[22] Robert Garza,[23] Robert Pruett, Robert Thompson,[24] Rodolfo Medrano,[25] Steven Woods, and Ignacio Cuevas.[26]

Kenneth Foster and Miguel Martinez's sentences would later be commuted to life imprisonment. Clinton Young was released on bond in January 2022 after his conviction was overturned in September 2021.[27]

See also

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References

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  1. ^ "Texas Penal Code Section 7.02, Criminal Responsibility for Conduct of Another". 2016. Retrieved August 1, 2016.
  2. ^ "Texas Penal Code Section 37.071, Procedure in Capital Case". 2016. Retrieved August 2, 2016.
  3. ^ "Texas Action". 2021. Retrieved May 5, 2021.
  4. ^ "Texas Legislature". 2023. Retrieved June 5, 2023.
  5. ^ "Executed But Did Not Directly Kill Victim". Retrieved 5 June 2023.
  6. ^ "Trevino v. Thaler". Retrieved 14 November 2011.
  7. ^ "State of Texas Executes Cleve Foster". Retrieved 5 June 2023.
  8. ^ "Clinton Lee Young Inmate Information". 2003. Retrieved April 15, 2003.
  9. ^ "Texas executes one of the "Texas Seven" prison escapees". Retrieved 18 December 2018.
  10. ^ "Executed But Did Not Directly Kill Victim". Retrieved 5 June 2023.
  11. ^ "Texas executes one of the "Texas Seven" prison escapees". Retrieved 18 December 2018.
  12. ^ "Executed But Did Not Directly Kill Victim". Retrieved 5 June 2023.
  13. ^ "The death penalty protested in Texas for the 21st year". Retrieved 19 October 2019.
  14. ^ "Executed But Did Not Directly Kill Victim". Retrieved 5 June 2023.
  15. ^ "Document – USA (Texas): Death Penalty / Legal Concern". amnesty.org. 2011. Retrieved September 14, 2011.
  16. ^ "Texas executes one of the "Texas Seven" prison escapees". Retrieved 18 December 2018.
  17. ^ "Document – USA: Breaking a Lethal Habit: A Look Back at the Death Penalty in 2007". amnesty.org. 2011. Retrieved September 14, 2011.
  18. ^ "Document – USA: One County, 100 Executions: Harris County and Texas – A Lethal Combination". amnesty.org. 2011. Retrieved September 14, 2011.
  19. ^ "The death penalty protested in Texas for the 21st year". Retrieved 19 October 2019.
  20. ^ "Texas executes one of the "Texas Seven" prison escapees". Retrieved 18 December 2018.
  21. ^ "Laredo's 'Triple-Ax Murders' Detailed in New Netflix Docuseries". Retrieved 14 August 2018.
  22. ^ "A Letter From Ray Jasper Who Is About to Be Executed". gawker.com. 2014. Archived from the original on March 5, 2014. Retrieved March 5, 2014.
  23. ^ "Robert Garza Executed". Retrieved 19 September 2019.
  24. ^ "Document – USA: Choosing Death Again: Texas Governor Rejects Clemency Recommendation". amnesty.org. 2011. Retrieved September 14, 2011.
  25. ^ "The death penalty protested in Texas for the 21st year". Retrieved 19 October 2019.
  26. ^ "Texas Inmate Sentenced to Die In Killing of Hostage in Shootout". The New York Times. 1975-04-05. ISSN 0362-4331. Retrieved 2023-06-15.
  27. ^ "Clinton Lee Young Released". 2021. Retrieved January 1, 2021.
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