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Ex Parte Robert Burns Springfield IV, 03-14-00739-CV (TexApp Dist 12/21/2016)

Claimant Robert Burns Springsteen IV was sentenced to death in the infamous 1991 Austin yogurt shop murders of four teenage girls. He was released from prison after a subsequent U.S. Supreme Court decision regarding the confrontation clause, Crawford v. Washington (541 U.S. 36), which rendered inadmissible a written statement from his co-defendant implicating him in the murders. The claimant then sought compensation for his time in prison under a Texas statute that imposed a ministerial duty on comptroller to grant it under certain conditions, with appeal only to Texas Supreme Court. The relevant portion of the statute required that a prisoner be released "in accordance with a writ of habeas corpus" and was actually innocent of the crime. The comptroller denied his claim, concluding he had failed to establish these requirements. Instead of turning to the Supreme Court, claimant sued the comptroller in the U.S. Court for the Western District of Texas on due process grounds, but was dismissed for lack of jurisdiction, lack of standing, and sovereign immunity. Claimant then filed in state district court under the Uniform Declaratory Judgments Act. Although he filed a purported ex parte claim with no defendants, in an apparent attempt to get around sovereign immunity, the Travis county prosecutor filed an opposition to his claim. The district court granted the prosecutor's plea to the jurisdiction, and claimant appealed. The appeals court found that the UDJA does not "enlarge" a trial court's jurisdiction. Therefore, the trial court did not have jurisdiction to hear claimant's due-process argument, nor his argument that release from prison is effectively "in accordance with" a habeas corpus determination even though no such judgment was issued, nor to determine his actual innocence under the compensation statute. The court affirmed the trial court's dismissal. Ex Parte Robert Burns Springfield IV, Austin Court of Appeals, Case No. 03-14-00739-CV, 12/21/16.

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