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 … Continue reading “Reply Brief in Support of Petition for a Writ of Certiorari”

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 … Continue reading “Cert Petition For a Writ of Certiorari”

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 … Continue reading “Declaration of John Wixted, Ph.D about Charles Don Flores’ Case”

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 … Continue reading “Pleading to oppose the request for the execution date”

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 … Continue reading “2nd Subsequent Application for Writ of Habeas Corpus”

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 … Continue reading “Petition For a Writ of Certiorari to The Texas Court of Criminal Appeals”

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 … Continue reading “Objections to District Court Judge’s Recommendations”

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 … Continue reading “Amicus Curiae Brief filed by the Innocence Project”