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Criminal Law keyed to Dripps
Hanks v. State
Facts
Hanks and P.F. Dillman (Defendants) were indicted in Travis County, Texas, for the forgery of a transfer of land certificate for property located in Texas. However, all of the acts constituting the forgery were committed in the State of Louisiana. Article 451 of the Texas Penal Code allowed the state to assert jurisdiction over those individuals who commit criminal acts outside the state but which cause injury within Texas. Prior to trial, Defendants filed a motion to quash the indictment, claiming the Texas Legislature lacked the authority to pass the law and assume jurisdiction over acts committed outside the state’s boundaries. Defendants were convicted and they appealed.
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