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Supreme Court Unanimously Upholds Texas Murder Conviction Under Limited Recess Rule

The justices said a judge’s order barring discussion of a defendant’s remaining testimony during an overnight break did not violate the right to counsel.

David Asa Villarreal weeps as prosecutor Kimberly Gonzalez shows him a picture of his boyfriend, Aaron Estrada, in court on June 22, 2018. The U.S. Supreme Court has upheld  Villarreal's murder conviction in Estrada's death.
David Asa Villarreal was convicted in 2016 in the stabbing death of Aaron Estrada. The U.S. Supreme Court has upheld that conviction.
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In June 2018, David Asa Villarreal (pictured) was convicted and sentenced to 60 years in prison following the 2015 stabbing death of his boyfriend, Aaron Estrada.

Overview

  • The ruling leaves David Asa Villarreal’s 60-year sentence in place for the 2015 killing of Aaron Estrada, with parole eligibility only after half the term is served.
  • Justice Ketanji Brown Jackson wrote the opinion for a 9-0 Court, with separate concurrences from Justices Samuel Alito and Clarence Thomas, and Justice Neil Gorsuch joining Thomas’s concurrence.
  • The Court held that restricting discussions that would manage ongoing testimony during a recess permissibly balances the Sixth Amendment with the need for unaltered witness testimony while allowing other attorney-client consultation.
  • The decision affirms prior rulings by the Fourth Court of Appeals and the Texas Court of Criminal Appeals, after Bexar County Assistant District Attorney Andrew Warthen argued the case before the justices in October.
  • Trial evidence showed Estrada was stabbed seven times in the neck and head; the defense claimed self-defense during a drug-fueled struggle, and prosecutors highlighted Villarreal’s failure to call police and his drive to Austin.