- 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 death row, ...
- 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.
The State obtained Charles Don Flores’s conviction based primarily on a mid-trial, in-court “identification,” made for ...
- 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 ...
- 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 State’s Latest ...
- 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 argument, reputedly ...
- 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 ...
- 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
- 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
- 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 and law enumerated ...
- Amicus Curiae Brief filed by the Innocence Project
The Innocence Project brief agrees that the scientific understanding of memory and the ability of hypnosis to distort memory and inflated confidence in false memories has developed considerably since the time of Charles’s trial.
Download the Amicus Curiae Brief in PDF filed by the Innocence Project in support of Charles Don Flores.
Download Brief of Amici Dr. ...
- Designed To Break You Report by Human Rights Clinic
Human Rights Violations on Texas’ Death Row – By Human Rights Clinic, University of Texas School of Law
The State of Texas stands today as one of the most extensive utilizers of the death penalty worldwide. Consequently, inmate living conditions on Texas’ death row are ripe for review. This report (download in PDF) demonstrates that the ...
- 2016 Charles Don Flores Final Appeal
On May 18th, 2016, Charles Don Flores’ attorney filed his final appeal focusing on the issue that the hypnotized witnesses false identification was unreliable, the Texas Court of Criminal Appeal issued a stay of execution and ordered an evidentiary hearing on the issue of junk science/hypnosis.
Download this legal document in PDF