- Tex. Crim. App.
- Cochran, J.,
The court of appeals held, under the judicially created De Garmo
doctrine as modified by Leday
, that appellant was estopped from complaining about the state's jury argument during the guilt phase because he had later admitted his guilt. A defendant who testifies at the punishment stage of trial and admits his guilt does not forfeit his right to complain on appeal about errors occurring during the guilt stage. The court of appeals' judgment is reversed and remanded. Court of Criminal Appeals, No. PD-1466-11, 02-06-2013.