Alcorta v. Texas

Background

A man, Alvaro Alcorta, was convicted and sentenced to death in Texas for stabbing his wife. He admitted killing her but said he acted in a sudden fit of passion after finding her kissing another man, Natividad Castilleja, which under Texas law could reduce the crime to a lesser offense. At trial Castilleja testified that he was only a casual friend and not romantically involved, testimony that conflicted with the defendant’s account. After the conviction, Castilleja signed a sworn statement saying he had lied; at a habeas hearing he admitted he had sexual relations with the wife and said he had told the prosecutor before trial. The prosecutor confirmed he knew of that relationship and told the witness not to volunteer the information, but he did not tell the defense.

Reasoning

The Court examined whether allowing the witness to testify falsely, with the prosecutor’s knowledge, violated the defendant’s right to a fair trial (due process). Relying on prior decisions, the Court found the false testimony was seriously prejudicial because it undermined the defendant’s passion-based defense that could have reduced the charge and prevented the death penalty. Because the prosecutor knew of the falsehood and the false testimony likely affected the outcome, the Court concluded the conviction could not stand.

Real world impact

The Court reversed the judgment and sent the case back to the Texas Court of Criminal Appeals for further proceedings. The decision means that when prosecutors allow or fail to correct a witness’s known false testimony, convictions and sentences—including death sentences—may be overturned. This ruling does not dispose of the guilt question on the merits; it requires additional state-court proceedings consistent with the Court’s opinion.