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The State of Texas v. Natalie Faith Trujillo

2026-08-19

Summary

Holding. The court dismissed the State's appeal for lack of jurisdiction because the prosecutor failed to include the required certification in the notice of appeal filed within the twenty-day deadline, and the State v. Redus requirement for this certification has not been abrogated.

Texas filed a timely notice of appeal from a trial court order suppressing evidence, but the notice failed to include the prosecutor's certification required by Texas Code of Criminal Procedure Article 44.01(a)(5). The State later argued that a recent Texas Court of Criminal Appeals decision in State v. Lambert had abrogated the jurisdictional requirement for this certification. The Fourth Court of Appeals rejected this argument, finding Lambert distinguishable because it involved an appeal from an order granting a new trial rather than a suppression order, and noting that Lambert contained no mention of overruling the controlling precedent in State v. Redus.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether the prosecutor's certification is a jurisdictional requirement in appeals from orders granting motions to suppress evidence
  • Whether State v. Lambert abrogated State v. Redus
  • Whether defects in the notice of appeal can be corrected through late amendment

Procedural posture

The State of Texas appealed the trial court's order granting the defendant's motion to suppress evidence, but the appeal was dismissed for lack of jurisdiction on grounds of a defective notice of appeal.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Fourth Court of Appeals

San Antonio, Texas

OPINION

No. 04-26-00161-CR

The STATE of Texas,

Appellant

v.

Natalie Faith TRUJILLO,

Appellee

From the County Court at Law No. 4, Bexar County, Texas

Trial Court No. 2025-CC-006386

Honorable Alfredo Ximenez, Judge Presiding

Opinion by: Rebeca C. Martinez, Chief Justice

Sitting: Rebeca C. Martinez, Chief Justice

Irene Rios, Justice

Lori I. Valenzuela, Justice

Delivered and Filed: August 19, 2026

DISMISSED

On March 2, 2026, the State filed a notice of appeal from the trial court’s February 12,

2026 order granting Natalie Faith Trujillo’s motion to suppress evidence. See TEX. CODE CRIM.

PROC. ANN. art. 44.01(a)(5). The Texas Code of Criminal Procedure provides that when appealing

an order granting a motion to suppress evidence, the prosecuting attorney must “certif[y] to the

trial court that the appeal is not taken for the purpose of delay and that the evidence” “is of

04-26-00161-CR

substantial importance to the case.” See id. Although the State’s notice of appeal was timely filed,

it failed to include the certification required by Article 44.01(a)(5).

In State v. Redus, 445 S.W.3d 151, 156 (Tex. Crim. App. 2014), the Texas Court of

Criminal Appeals held:

. . substantive defects in the State’s notice of appeal cannot be corrected by an

untimely amendment. Any amendment must be made before the expiration of the

original time to file notice of appeal, that is, within twenty days after entry of the

trial judge’s ruling. Because the prosecuting attorney’s certification is

jurisdictional, the State’s appeal must be dismissed for want of jurisdiction if the

proper certification is not filed within twenty days after the trial court enters its

order suppressing evidence.

Id. (footnotes omitted) (citations omitted)

On April 29, 2026, we ordered the State to show cause why its appeal should not be

dismissed for lack of jurisdiction in light of Redus and its progeny. See id.; see also State v.

Vannoord, No. 06-17-00107-CR, 2017 WL 3382333, at *2 (Tex. App.—Texarkana Aug. 1, 2017,

no pet.) (mem. op., not designated for publication) (“Because the State’s original notice of appeal

did not confer jurisdiction on this Court and because the State was not allowed to amend a

jurisdictional element of her notice after expiration of the filing deadline, the State failed to invoke

this Court’s jurisdiction, and we are left with no choice but to dismiss this appeal.”); State v.

Rodriguez, No. 14-13-00766-CR, 2014 WL 5309661, at *1 (Tex. App.—Houston [14th Dist.] Oct.

16, 2014, no pet.) (mem. op., not designated for publication) (dismissing the State’s appeal for

lack of jurisdiction when the elected prosecutor’s certification did not comply with article

44.01(a)(5)). The State responded with a motion to dismiss its appeal.

On May 26, 2026, the State filed a Motion to Withdraw its Motion to Dismiss. The State’s

motion to withdraw alerted us to State v. Lambert, No. PD-0832-24, 2026 WL 1424212 (Tex.

Crim. App. May 21, 2026), reh’g denied (Jul. 23, 2026), and requested “time to review whether

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[State v. Redus, 445 S.W.3d 151, 155–56 (Tex. Crim. App. 2014)] has been abrogated [by

Lambert] and, if so, to outline to the Court why the appeal should not be dismissed.”

On May 27, 2026, we issued a memorandum opinion granting the State’s motion to

dismiss. The State’s motion to withdraw was not processed until May 28, 2026. Upon review of

the State’s motion to withdraw, we withdrew our previously issued memorandum opinion and

judgment, reinstated the appeal, and ordered the parties to brief the jurisdictional question. Both

parties have complied with our request for jurisdictional briefing. The State generally contends

that “Lambert abrogates Redus.” Trujillo argues that “State v. Lambert never even mentions State

v. Redus — much less overrules it.”

In Lambert, 2026 WL 1424212 at *1, a jury convicted the defendant on a count of sexual

assault of a child, but the trial court granted the defendant’s motion for new trial. The duly elected

district attorney signed and caused to be filed a timely notice of appeal that referenced a different

date than the date the new trial order had been signed and referenced a “Judgment” that was,

according to the notice, a “dismissal of the information based on a supposed defect” in the

information. Id. The Texas Court of Criminal Appeals presumed that the State used a different

document as a template and “forgot to change the substantive text.” Id. at *1, n.2. The appellee

moved to dismiss the State’s appeal and the intermediate appellate court held that appellate

jurisdiction existed. Id. at *1. The Texas Court of Criminal Appeals affirmed on two grounds.

Id. at *4–5. First, the court held that “after the trial court granted Appellee’s motion for new trial,

it was the only appealable ruling under the record’s context that the State could contest.” Id. at *4.

Second, the court emphasized that Texas Rule of Appellate Procedure 25.2(f) provides, “[a]n

amended notice of appeal . . . correcting a defect or omission in an earlier filed notice . . . may be

filed in the appellate court . . . at any time before the appealing party’s brief is filed.” Id. The

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court noted that the “defect” in the State’s notice of appeal may be properly amended under Texas

Rule of Appellate Procedure 25.2(f).

The State’s jurisdictional position fails for three reasons. First, Lambert is distinguishable

from Redus because Lambert deals with an appeal from an order granting a new trial and Redus

deals with an order granting a defendant’s motion to suppress. An appeal from an order granting

a motion to suppress is subject to a different subsection of Article 44.01, which states:

The state is entitled to appeal an order of a court in a criminal case if the order . . .

grants a motion to suppress evidence, a confession, or an admission, if jeopardy

has not attached in the case and if the prosecuting attorney certifies to the trial

court that the appeal is not taken for the purpose of delay and that the evidence,

confession, or admission is of substantial importance in the case[.]

TEX. CODE CRIM. PROC. ANN. art. 44.01(a)(5) (emphasis added). The subsection relating to an

appeal from an order granting a new trial contains no such certification provision. Second, as

appellee notes, Lambert makes no mention of Redus, much less overrules it. Third, in 2025, the

Texas Legislature amended Article 44.01 to include provisions relating to appeals regarding bail.

See Acts 2025, 89th Leg., ch. 339 (S.B. 9), § 15, eff. Sept. 1, 2025. “When the Legislature revises

a particular statute that has been judicially construed, without changing the construed language, it

is presumed that the Legislature intended that the same construction should continue to be applied

to that statute.” Watkins v. State, 619 S.W.3d 265, 281 (Tex. Crim. App. 2021). Thus, we are to

presume that the amendments from last year reaffirmed the holding in Redus.

Under Redus, 445 S.W.3d at 156, we lack jurisdiction over the State’s attempt to appeal

from the trial court’s order granting appellee’s motion to suppress. Accordingly, we dismiss this

appeal.

Rebeca C. Martinez, Chief Justice

PUBLISH

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