- 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