Legal Documents
Motion For Access To Evidence To Conduct DNA Testing
Filled by Gretchen S. Sween on September 9th, 2022 Charles Don Flores is currently confined on Texas’s death row pursuant to the judgment of the 195th District Court, Dallas County, Texas, entered in 1999. By and through counsel, Flores files this Motion for Access to Evidence to Conduct DNA Testing pursuant to Chapter 64 of ... Read More
Reply Brief in Support of Petition for a Writ of Certiorari
Filled on May 24th, 2022 The State’s Brief in Opposition (BIO) contains no cogent legal argument. It relies on a stream-of-consciousness jumble of “facts,” cherry-picked largely from a trial record that is the product of prosecutorial misconduct and junk science. Presumably, the State’s goal is to suggest that the case of an indigent individual on ... Read More
Cert Petition For a Writ of Certiorari
Filed on March 4th, 2022 Charles Don Flores is again endeavoring to be heard by the highest court in the United States after the state courts refused to consider all the new evidence demonstrating his wrongful conviction and factual innocence. QUESTIONS PRESENTED The State obtained Charles Don Flores’s conviction based primarily on a mid-trial, in-court ... Read More
Declaration of John Wixted, Ph.D about Charles Don Flores’ Case
John Wixted is a Distinguished Professor of Psychology at the University of California–San Diego (UCSD). His current research is concerned with the understanding of episodic memory. He investigates the cognitive mechanisms that underlie recognition memory, often using signal detection theory as a guide. A related line of research involves investigating how episodic memory is represented ... Read More
Pleading to oppose the request for the execution date
Filed on April 6th, 2021 CHARLES DON FLORES’S RESPONSE IN OPPOSITION TO THE STATE’S LATEST MOTION TO SET EXECUTION DATE On Good Friday, April 2, 2021, the Dallas County District Attorney’s Office elected to file, on the State’s behalf, a Renewed Motion to Set Execution Date (Latest Execution Motion). In light of the circumstances, the ... Read More
2nd Subsequent Application for Writ of Habeas Corpus
Filed on February 3rd, 2021 Applicant Charles Don Flores is currently confined on death row in the Texas Department of Criminal Justice’s Polunsky Unit in Livingston, Texas. His wrongful conviction was obtained in a trial plagued by police and prosecutorial misconduct and where his insistence on his innocence was overridden by trial counsel in closing ... Read More
Petition For a Writ of Certiorari to The Texas Court of Criminal Appeals
In Rock v. Arkansas, 483 U.S. 44 (1987), this Court found that, although “hypnotically refreshed” testimony was “controversial,” the dangers associated with it could be reduced by “procedural safeguards” that this Court left to the states to adopt. Contemporary scientific understanding of human memory and of the inherently intrusive nature of hypnosis has established that ... Read More
Texas CCA Request to Review Hypnosis Video
January 22nd, 2020 The Texas Court of Criminal Appeals (CCA)of Texas is reviewing key evidence relevant to the appeal and is requesting to see the hypnosis video: Download CCA order in PDF ... Read More
Motion to File and Set for Briefing and Request for Oral Argument
Download motion filed on December 10, 2018 Download supplement to motion filed on April 04, 2019 ... Read More
Objections to District Court Judge’s Recommendations
Applicant Charles Flores, by and through counsel, respectfully requests that this Honorable Court: consider the objections presented here; withdraw its Order dated October 3, 2018 (Order), which includes Findings of Fact and Conclusions of Law (FFCL) and contains a recommendation that habeas corpus relief be denied; enter revised FFCL correcting the significant mistakes of fact ... Read More