In Re Rebel Hayz Breaux v. the State of Texas

CourtTexas Court of Appeals, 9th District (Beaumont)
DecidedMay 6, 2026
Docket09-26-00148-CR
StatusPublished

This text of In Re Rebel Hayz Breaux v. the State of Texas (In Re Rebel Hayz Breaux v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 9th District (Beaumont) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Rebel Hayz Breaux v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-26-00148-CR __________________

IN RE REBEL HAYZ BREAUX

__________________________________________________________________

Original Proceeding 163rd District Court of Orange County, Texas Trial Cause No. 250302-C __________________________________________________________________

MEMORANDUM OPINION

Relator Rebel Hayz Breaux petitions for a writ of mandamus to compel the

trial court to vacate its order denying an application for a writ of habeas corpus, issue

a writ of habeas corpus pursuant to article 11.09 of the Texas Code of Criminal

Procedure, rule on Breaux’s motion for appointment of counsel, and hold an

evidentiary hearing. We conditionally grant partial relief, as explained below.

On August 19, 2024, in Cause Number 240284-R in the 163rd District Court,

Breaux pleaded guilty and was convicted of a lesser included offense of Assault

Family Violence. In March 2025, Breaux filed an application for a writ of habeas

corpus that the District Clerk filed as Cause Number 240284-R. The trial court

1 denied the application because Breaux had discharged his sentence and was not

currently being restrained by any party due to his conviction in Trial Cause Number

240284-R. See Ex parte Breaux, No. 09-25-00117-CR, 2025 WL 1450715, at *1

(Tex. App.—Beaumont May 21, 2025, no pet.) (mem. op., not designated for

publication). This Court dismissed Breaux’s appeal for lack of jurisdiction. Id. We

noted that Breaux failed to identify a collateral consequence of his conviction that

restrains his liberty in his application to the trial court. Id.

In August 2025, Breaux filed a new article 11.09 application which the

District Clerk filed as Trial Cause Number 250302-C. In his application, Breaux

alleged that he is subject to “significant and ongoing restraints on his liberty flowing

directly from the challenged conviction,” including a lifetime federal firearm

prohibition and a final protective order. Breaux challenged the conviction in Trial

Cause Number 240284-R on grounds of ineffective assistance of counsel,

involuntariness of his guilty plea, and actual innocence.

The trial court again denied the application because Breaux’s sentence had

been discharged and he was not currently being restrained by any party due to his

conviction in Trial Cause Number 240284-R, and Breaux filed a notice of appeal.

See Ex parte Breaux, No. 09-25-00322-CR, 2026 WL 916592, at *1 (Tex. App.—

Beaumont Apr. 1, 2026, no pet. h.). This Court dismissed Breaux’s appeal for lack

of jurisdiction because the trial court denied Breaux’s article 11.09 application

2 without issuing the writ or ruling on Breaux’s claims. Id. On April 1, 2026, Breaux

filed a motion for rehearing in Appeal Number 09-25-00322-CR and on April 7,

2026, a petition for a writ of mandamus that the Clerk of this Court assigned Number

09-26-00148-CR. We requested a response from the State regarding the mandamus

petition.

To obtain mandamus relief in a criminal case, the relator must show that he

has no adequate remedy at law and what he seeks to compel is ministerial, involving

no discretion. In re State ex rel. Best, 616 S.W.3d 594, 599 (Tex. Crim. App. 2021)

(orig. proceeding). In his mandamus petition, Breaux contends the trial court abused

its discretion by denying the article 11.09 application in Trial Cause Number

250302-C because he sufficiently alleged collateral consequences of the conviction

that constitute a restraint on his liberty. In response to Breaux’s mandamus petition,

the State concedes that by pleading in his second application that he is subject to a

lifetime firearm ban as a consequence of his conviction, Breaux sufficiently pleaded

that he is currently restrained due to a collateral consequence of his conviction. See

Tex. Code Crim. Proc. Ann. Art. 11.22 (“By ‘restraint’ is meant the kind of control

which one person exercises over another, not to confine him within certain limits,

but to subject him to the general authority and power of the person claiming such

right.”); see also 18 U.S.C. § 922(g)(9) (“It shall be unlawful for any person . . . who

has been convicted in any court of a misdemeanor crime of domestic violence, to

3 . . . possess in or affecting commerce, any firearm[.]”; see also In re A.R.C., 685

S.W.3d 80, 83 (Tex. 2024) (Although the appellant was no longer involuntarily

committed, appeal challenging court-ordered mental health services was not moot

because an involuntary-commitment order imposes collateral consequences under

federal and state law, for example, 18 U.S.C. § 922(g)(9)). Thus, the State concedes

the trial court abused its discretion in denying the writ application for the reason

stated in the trial court’s Order dated August 27, 2025. Breaux lacks a remedy by

appeal. See Ex parte Breaux, 2026 WL 916592, at *1.

Breaux additionally argues the trial court abused its discretion by refusing to

issue the writ, conduct an evidentiary hearing, rule on the merits of Relator’s

constitutional claims, or rule on Breaux’s Motion for Appointment of Counsel. The

State does not concede this issue and argues article 11.09 does not require a trial

court to hold an evidentiary hearing. As supporting authority, the State cites an

unpublished opinion from another jurisdiction. See Ex parte Oliver, No. 05-09-

00611-CR, 2009 WL 3210710, at **2-3 (Tex. App.—Dallas Sept. 21, 2009, pet.

ref’d) (mem. op., not designated for publication). In Oliver, the appellate court was

comparing the lack of procedural requirements in article 11.09 to the procedural

requirements contained in article 11.072. See id. Applying the presumption of

regularity of trial court proceedings, the appellate court presumed the trial court

reviewed the documents that were part of the trial court’s file before ruling on the

4 application for writ of habeas corpus. Id. at *3. We do not read Oliver as support for

an argument that a trial court need not consider evidence if on its face the writ

application demonstrates there are issues of fact that must be resolved.

To be entitled to consideration of the merits of the writ application, however,

Breaux must comply with the requirements set forth in article 11.14 of the Texas

Code of Criminal Procedure. See Tex. Code Crim. Proc. Ann. Art. 11.14

(Application Requirements). The application requirements of article 11.14 are not

jurisdictional. Ex parte Golden, 991 S.W.2d 859, 862 (Tex. Crim. App. 1999). In

Golden, the Court of Criminal Appeals considered the merits of Golden’s unverified

article 11.07 application where the State did not move to dismiss the application and

conceded applicant was entitled to relief, the trial court made relevant fact findings,

and there was adequate proof in the record to support the applicant’s claims. Id. fn.2.

That said, the habeas court may in its discretion deny a defective application. See id.

at 861 (“In the past, we have denied relief in some cases and dismissed in others.”).

To establish his entitlement to a writ of habeas corpus “[o]ath must be made

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Related

Ex Parte Golden
991 S.W.2d 859 (Court of Criminal Appeals of Texas, 1999)

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In Re Rebel Hayz Breaux v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-rebel-hayz-breaux-v-the-state-of-texas-txctapp9-2026.