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In Re William Penn Dixon v. State of Texas

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Summary

William Penn Dixon, proceeding pro se, filed a petition for writ of habeas corpus with the Texas Court of Appeals, 10th District (Waco), challenging a pending criminal case based on an alleged illegal search. The Court dismissed the petition for want of jurisdiction, citing Texas Government Code § 22.221(d), which provides that intermediate appellate courts do not have original habeas corpus jurisdiction in criminal law matters. The Court noted that jurisdiction to grant habeas corpus in criminal cases vests with the Court of Criminal Appeals, district courts, county courts, or any judge in those courts.

“Intermediate appellate courts do not have original habeas corpus jurisdiction in criminal law matters.”

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The Texas Courts of Appeals are intermediate appellate courts that hear every appeal from Texas district and county courts before cases reach the Texas Supreme Court or Court of Criminal Appeals. Together they publish around 290 opinions a month across civil, criminal, family, probate, and administrative cases. Texas's economy and legal volume mean the courts generate significant precedent on energy, oil and gas, commercial real estate, employment, and family law that affects multistate clients. GovPing tracks every published opinion via CourtListener's mirror, with case name, parties, court division, and outcome. Watch this if you litigate in Texas, advise on energy or land disputes, or track how Texas courts treat federal questions in commercial cases.

What changed

The Texas Court of Appeals, 10th District (Waco) dismissed William Penn Dixon's pro se petition for writ of habeas corpus for want of jurisdiction. The Court held that intermediate appellate courts lack original habeas corpus jurisdiction in criminal law matters under Texas Government Code § 22.221(d), and that such jurisdiction rests exclusively with the Court of Criminal Appeals, district courts, county courts, or judges thereof. The Court also noted that a defendant represented by court-appointed counsel is not entitled to hybrid representation. The petition is dismissed, and the ruling does not address the merits of Dixon's underlying claims regarding an illegal search.

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Apr 24, 2026

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April 23, 2026 Get Citation Alerts Download PDF Add Note

In Re William Penn Dixon v. the State of Texas

Texas Court of Appeals, 10th District (Waco)

Disposition

Dismissed-Want of Jurisdiction

Lead Opinion

Court of Appeals
Tenth Appellate District of Texas

10-26-00131-CR

In re William Penn Dixon

Original Proceeding

JUSTICE SMITH delivered the opinion of the Court.

MEMORANDUM OPINION

William Penn Dixon, proceeding pro se, filed a document entitled

“Petition for Writ of Habeas Corpus” with this Court. He claims that the

Brazos County District Clerk has refused to file his pro se petition for writ of

habeas corpus and that the trial court has refused to hold a hearing on the

petition, in which Dixon claims that the trial court should dismiss his pending

criminal charges based on an illegal search. He asks that we “order the trial

court to respond to the writ” and “send findings of facts [sic],” and further

requests that we suppress the evidence and dismiss the charges.

Intermediate appellate courts do not have original habeas corpus

jurisdiction in criminal law matters. See TEX. GOV’T CODE ANN. § 22.221(d).

Jurisdiction to grant a writ of habeas corpus in a criminal case vests with the
Court of Criminal Appeals, the district courts, the county courts, or any judge

in those courts. See TEX. CODE CRIM. PROC. ANN. art. 11.05; Ex parte Braswell,

630 S.W.3d 600, 601-02 (Tex. App.—Waco 2021, orig. proceeding).1

Accordingly, we dismiss Dixon’s petition for writ of habeas corpus for

want of jurisdiction.

STEVE SMITH
Justice

OPINION DELIVERED and FILED: April 23, 2026
Before Chief Justice Johnson,
Justice Smith, and
Justice Harris
Dismissed
Do not publish
OT06

1 We note that Dixon also indicated in his petition that he is represented by court-appointed trial

counsel and that appointed counsel refused to file a motion to suppress on his behalf. Though Dixon
questions his appointed counsel’s qualifications, a defendant represented by counsel is not entitled to
hybrid representation. See Robinson v. State, 240 S.W.3d 919, 922 (Tex. Crim. App. 2007).

In re William Penn Dixon Page 2

Named provisions

Original Habeas Corpus Jurisdiction Hybrid Representation

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Last updated

Classification

Agency
TX 10th Dist. Ct.
Filed
April 23rd, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Docket
10-26-00131-CR

Who this affects

Applies to
Criminal defendants
Industry sector
9211 Government & Public Administration
Activity scope
Habeas corpus petition Criminal procedure Appellate jurisdiction
Geographic scope
Texas US-TX

Taxonomy

Primary area
Criminal Justice
Operational domain
Legal
Topics
Judicial Administration Criminal Justice

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