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Christina Thompson v. State of Texas - Deadly Conduct Appeal

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Filed March 13th, 2026
Detected March 17th, 2026
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Summary

The Texas Court of Appeals, 3rd District, has abated and remanded the appeal of Christina Thompson v. State of Texas. The court is ordering a hearing to determine the appellant's desire to prosecute the appeal and her indigency status for the reporter's record.

What changed

The Texas Court of Appeals, 3rd District, has abated and remanded the criminal appeal of Christina Thompson v. State of Texas (Docket No. 03-25-00265-CR). The court's decision stems from the appellant's appointed counsel's inability to contact her and the appellant's repeated failure to pay for the reporter's record, despite multiple extensions. The appeal is abated to the trial court to conduct a hearing on the appellant's desire to proceed with the appeal and her indigency status.

This action requires the trial court to hold a hearing, make findings, and potentially appoint new counsel if the appellant is found indigent. Legal professionals involved in similar appeals should note the importance of ensuring clients are reachable and that necessary records are secured, as failure to do so can lead to abatement and remand. The outcome of the trial court's hearing will determine the future of this appeal.

What to do next

  1. Trial court to conduct hearing on appellant's desire to prosecute appeal and indigency status.
  2. Trial court to make written findings and recommendations.
  3. Trial court to appoint substitute counsel if necessary.

Source document (simplified)

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Top Caption Disposition Lead Opinion

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March 13, 2026 Get Citation Alerts Download PDF Add Note

Christina Thompson v. the State of Texas

Texas Court of Appeals, 3rd District (Austin)

Disposition

Abated and Remanded

Lead Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-25-00265-CR

Christina Thompson, Appellant

v.

The State of Texas, Appellee

FROM THE COMAL COURT AT LAW NO. 3 OF COMAL COUNTY
NO. 2023CR0771, THE HONORABLE DEBORAH WIGINGTON, JUDGE PRESIDING

ORDER AND MEMORANDUM OPINION

PER CURIAM

Pending before this Court are two motions: appointed appellate counsel’s motion

to withdraw, asserting that she has not been able to contact appellant since October 2025, and

appellant’s third motion for extension of time to file appellant’s brief. Appellant, although

declared indigent for purposes of appellate counsel, was apparently found not indigent for

purposes of the reporter’s record. See McFatridge v. State, 309 S.W.3d 1, 6 (Tex. Crim. App.

2010) (“A defendant can be found indigent for one purpose without being found indigent for the

other.”). Appellant has not paid for the reporter’s record even after three extensions of time to

pay for it granted by this Court. Appellant’s indigency status is unclear; appellant has

recognized in prior pleadings that the trial court found her not indigent for purposes of the

reporter’s record, but the record does not contain evidence supporting that non-indigence

determination. See id. (“After a defendant establishes a prima facie showing of indigency, ‘an
appellate court can uphold a trial court’s determination of non-indigence only if the record

contains evidence supporting such a determination.’”).

The appeal is abated and remanded to the trial court. The trial court shall conduct

a hearing to determine whether appellant desires to prosecute this appeal and, if so, whether

appellant is indigent. See Tex. R. App. P. 37.3, 38.8. The court shall make appropriate written

findings and recommendations. If necessary, the court shall appoint substitute counsel who will

effectively represent appellant in this appeal. Following the hearing, which shall be transcribed,

the trial court shall order the appropriate supplemental clerk’s and reporter’s records—including

all findings and orders—to be prepared and forwarded to this Court no later than April 27, 2026.

See id. R. 38.8(b)(3).

It is so ordered March 13, 2026.

Before Justices Triana, Kelly, and Ellis

Abated and Remanded

Filed: March 13, 2026

Do Not Publish

2

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
TX Courts
Filed
March 13th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Legal professionals Criminal defendants
Geographic scope
State (Texas)

Taxonomy

Primary area
Criminal Justice
Operational domain
Legal
Topics
Appellate Procedure Indigency

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