In Re Texas Department of Criminal Justice, Relator

Court of Criminal Appeals of Texas·Decided April 16, 2026·No. WR-97,366-01·Published

Opinion

IN THE COURT OF CRIMINAL APPEALS OF TEXAS

NO. WR-97,366-01

IN RE TEXAS DEPARTMENT OF CRIMINAL JUSTICE, Relator

ON MOTION FOR LEAVE TO FILE PETITION FOR WRIT OF MANDAMUS AND THE ACCOMPANYING PETITION IN CAUSE NO. 2019D03091

IN THE CRIMINAL DISTRICT COURT NO. 1 EL PASO COUNTY

Per curiam.

OPINION

We have before us a motion for leave to file a petition for writ of mandamus and accompanying petition. The Relator in this case is the Texas Department of Criminal Justice (TDCJ). Because this case involves a death sentence, TDCJ properly filed the motion and petition in this Court. See Padilla v. McDaniel, 122

S.W.3d 805, 808 (Tex. Crim. App. 2003).

BACKGROUND

Real Party in Interest Facundo Chavez was convicted of capital murder and sentenced to death in August 2023. The convicting court is the Criminal District Court No. 1 of El Paso County. The Respondent in this case is the elected judge of the convicting court, the Honorable Diane Navarrete.

Chavez’s direct appeal is pending in this Court. See Chavez v. State, No.

AP-77,117. As of the date of this opinion, Chavez has not yet filed an application for a postconviction writ of habeas corpus. See TEX. CODE CRIM. PROC. art. 11.071. But he does have postconviction habeas counsel: the Office of Capital and Forensic Writs (OCFW).

In August 2025, OCFW filed in the convicting court an ex parte motion for funds to hire a neuropsychologist. See id. § 3. Respondent granted that motion in October 2025. Upon retaining a neuropsychologist, OCFW arranged for “contact visit[s]” between Chavez and the neuropsychologist at the Polunsky Unit, one of TDCJ’s prison facilities, on February 9 and 10, 2026. 1 As February 9 approached, OCFW filed an ex parte motion asking the

1 Unless otherwise stated, all subsequent calendar dates in this opinion refer to the year 2026.

convicting court to compel TDCJ to remove Chavez’s restraints during those visits. On January 29, Respondent granted OCFW’s request, entering an “Ex Parte, Under Seal Order” (Ex Parte Unshackling Order) directing TDCJ “to remove Mr. Chavez’s restraints during his contact expert visits on February 9th and February 10th.” The Ex Parte Unshackling Order is at the heart of this mandamus action.

The following week, on February 5, TDCJ filed in this Court a “Motion to Stay Trial Court’s Ex Parte Discovery Order and Motion for an Expedited Ruling.” The motion asked us to “stay the [Ex Parte Unshackling Order] pending the disposition of TDCJ’s forthcoming petition for a writ of mandamus.” We granted this motion without a written order the following day (First Stay).

TDCJ then transmitted its mandamus pleadings to this Court on February 13, arguing that ex parte communications, including the Ex Parte Unshackling Order at issue in this case, are prohibited unless expressly authorized by law. See In re City of Lubbock, 666 S.W.3d 546, 556 (Tex. Crim. App. 2023). There being no express authorization within Article 11.071 for ex parte communications regarding contact visits or inmate shackling, “the trial court had a ministerial duty to deny Chavez’s ex parte motion to compel and any other request filed ex parte.” TDCJ therefore asked this Court to “direct [Judge Navarrete] to vacate” the Ex Parte

Unshackling Order.

But there was a problem. By the time TDCJ transmitted its mandamus pleadings, the Ex Parte Unshackling Order had expired—February 9 and 10 had come and gone, apparently with no expert visits taking place on those dates. There being no live controversy, this Court might have summarily dismissed TDCJ’s mandamus pleadings as moot. Yet TDCJ urged us not to do so, citing the “capable of repetition, yet evading review” exception to the mootness doctrine. See, e.g., Ex parte Bohannan, 350 S.W.3d 116, 119–20 (Tex. Crim. App. 2011).

Meanwhile, OCFW again arranged for contact visits between Chavez and the neuropsychologist at the Polunsky Unit, with these visits scheduled for March 9 and 10. On February 19—before we had taken any action on TDCJ’s mandamus pleadings—OCFW filed another motion asking the convicting court “to compel TDCJ to remove Mr. Chavez’s restraints during expert evaluation[s] on March 9th and 10th, 2026.” The motion claimed that it had been sent “to all parties” (i.e., not ex parte). The record suggests that the motion was at least sent to the El Paso County District Attorney’s Office.

On March 6, Judge Navarrete granted OCFW’s motion by entering an order (Public Unshackling Order) purporting to “vacate[]” the Ex Parte Unshackling Order. Like the Ex Parte Unshackling Order, the Public Unshackling Order directed TDCJ to remove Chavez’s restraints during his visits with his expert. But whereas the Ex Parte Unshackling Order referred to contact visits on February 9 and 10, the Public Unshackling Order referred to visits on March 9 and 10. The record suggests that a copy of the Public Unshackling Order was transmitted to various lawyers within the Attorney General’s Office (representing TDCJ in these proceedings) and the El Paso County District Attorney’s Office. OCFW promptly alerted this Court to the Public Unshackling Order.

And we promptly stayed it. “Such discovery orders” (i.e., the Ex Parte Unshackling Order and Public Unshackling Order), we said, “are STAYED pending this Court’s review and resolution of the mandamus matter before us.” In re Tex. Dep’t of Crim. Justice, No. WR-97,366-01 (Tex. Crim. App. Mar. 6, 2026) (not designated for publication) (Second Stay).

Our decision in this matter will therefore potentially affect at least four items: the First Stay, the Second Stay, the Ex Parte Unshackling Order, and the Public Unshackling Order. We note, however, that TDCJ has only initiated mandamus proceedings against the Ex Parte Unshackling Order. It has not sought mandamus relief from the Public Unshackling Order.

MOOTNESS

As mentioned, the Ex Parte Unshackling Order has expired. So, before moving on, we must decide whether to dismiss (or rather, deny leave to file) TDCJ’s mandamus petition as moot.

A case is moot when a justiciable controversy no longer exists between the parties or when the parties no longer have a legally cognizable interest in the outcome. Tex. Dep’t of Family & Protective Services v. N.J., 644 S.W.3d 189, 192 (Tex. 2022). When a case becomes moot, the court ordinarily loses jurisdiction and cannot consider the merits, because any resulting opinion would be advisory. See State ex rel. Best v. Harper, 562 S.W.3d 1, 6 (Tex. 2018).

But not always. Like the United States Supreme Court, see Weinstein v.

Bradford, 423 U.S. 147, 149 (1975), and our sister Court, see General Land Office of State of Tex. v. OXY U.S.A., Inc., 789 S.W.2d 569, 571 (Tex. 1990), we have recognized an exception to the mootness doctrine for claims that are “capable of repetition, yet evading review.” See Bohannan, 350 S.W.3d at 119. Under this exception, we may consider an otherwise moot claim when: (1) the challenged action was too short to be fully litigated before expiring; and (2) there is a reasonable expectation that the complaining party would face the same action again. See id. When both requirements are met, we may review the claim even though it may be technically moot.

Here, we find that TDCJ’s mandamus claim against the Ex Parte

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