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FABRICATION:
The Only Defense In Sexual Assault Cases Not Subject To Rebuttal Evidence, Keeping Extraneous Crimes, Wrongs, and Acts Out
By Criminal Defense Attorney John Floyd and Paralegal Billy Sinclair
Writing in her book “The Cross-Examination of a Young Child in a Sexual Assault Case: Voice for the Defense” (Oct. 1999), Annabelle Hall said that jurors following a sexual assault trial involving a child raise the following questions:
- Why would a child lie about sexual abuse?
- How can a child know so much about sex if she has not been abused?
- Would a child lie about sexual abuse?
- Why would a child make the story up?
These questions clearly demonstrate why a defense attorney in a sexual assault case faces such a difficult task establishing a “fabrication” defense. A “fabrication” defense in a sexual assault case is premised on the theory that the victim has “made up” or deliberately lied about the sexual assault. As difficult as it may be to logically wrap the mind around this concept, reliable studies (including the U.S. Justice Department) have revealed that anywhere between 25 to 60 percent of all sexual assault allegations are false. Put simply, somewhere between one-quarter to one-half of the rape allegations leveled in this country are fabricated for one reason or another. Many involve child victims.
Why would a child lie about such a thing?
In Cross-Examination of Child Witnesses, presented at the 19th Annual Rusty Duncan Advanced Criminal Law Short Course in San Antonio, Texas (June 15-17, 2006), Houston criminal defense attorney Stanley G. Schneider and Dallas doctor Mark Blotcky partially answered this question:
“False allegations of sexual abuse are usually simply incorrect. They are initiated by parents or a third party, e.g., this occurs due to the hyper-vigilence [sic] of parents of young children after their parents have been sensitized by sensational news media coverage of sexual abuse scandals. Pediatricians and child mental health professionals by law also make reports to Child Protective Services of any ‘suspected’ child abuse without having to confirm its veracity. They may be acting perfunctorily and simply reporting abuse based upon a small amount of information provided by the mother, the child, or exhibited by the child’s physical or behavioral symptoms. I know clinicians who feel compelled to report even when they believe it’s highly improbable that abuse has occurred. They are practicing defensive medicine. The report itself may then become overly weighted “evidence,” as though there had been some real investigatory work done or an expert professional opinion rendered about the abuse, though the report is simply conforming to the law to report any suspected child abuse.
Remember, very disturbed children, previously sexually abused children, bipolar children and others may exhibit eroticized behavior without being sexually abused. It is then easy to understand why a ‘third party’ makes a report.”
Once that initial sexual assault allegation is made, it assumes a life of its own and the “investigation” process is geared to give it legitimacy. Prosecutors readily accept these cases because convictions are fairly easy to obtain. Seasoned sexual assault prosecutors immediately began to scour the defendant’s past for other “extraneous offenses” of a similar nature or other “bad acts” that tend to shore up the defendant’s guilt before a jury. This is generally referred to as “other crimes” evidence. While the rules of evidence generally restrict this prejudicial evidence in the prosecution’s case in chief, the State can use it to rebut virtually every defense raised by the defendant, except the defense of “fabrication.” The law on this issue is well-established in Texas.
The Court of Criminal Appeals in Montgomery v. State, 810 S.W.2d 372 (Tex.Crim.App. 1990) held that Rule 404(b) of the Texas Rules of Criminal Evidence reflects a policy decision by the rule makers that evidence of extraneous misconduct at the guilt phase of trial having no relevance apart from inferences of character conformity is more prejudicial than probative as a matter of law, and trial court has no discretion to rule otherwise.
In deciding whether to admit evidence of extraneous offenses, the trial court must first find the offense or act relevant under 404 and then conduct a balancing test under Rule 403 of the Texas Rules of Criminal Evidence. This balancing test requires the court to weigh the probative value of the extraneous offense evidence against its undue prejudice, confusion of the issues, tendency to mislead the jury, and undue delay. See: Gigliobianco v. State, 210 S.W.3d 637, 642 (Tex.Crim.App. 2006).
The Court of Criminal Appeals has held that the following factors should be considered in a Rule 403 balancing analysis: (1) the strength of the evidence in making a fact more or less probable, (2) the potential of the extraneous-offense evidence to impress the jury in some irrational but indelible way, (3) the amount of time the proponent needed to develop the evidence, and (4) the strength of the proponent’s need for this evidence to prove a fact of consequence. See: Mozon v. State, 991 S.W.2d 841, 847 (Tex.Crim.App. 1999).
When the State files the mandatory “notice” that it will use extraneous sexual assault offenses, the trial court must conduct a Rule 403 balancing test before admitting the testimony of the witness testifying about the extraneous offenses. The trial court is not permitted to assess the credibility of the witness who will testify about the extraneous offenses based. Witness credibility is an issue solely for the jury to decide. See: Montgomery v. State, supra.
Citing Wright and Graham’s Federal Practice and Procedure, the court of criminal appeals explained: “[I]t seems relatively clear that in the weighing process under Rule 403 the judge cannot consider the credibility of the witnesses. In the first place, credibility is a question for the jury; to permit the judge to exclude evidence on the grounds that he thinks it incredible would be a remarkable innovation and may even be a violation of the right of trial by jury. In the second place even if the jury were not involved, in order to assess the credibility of a witness the judge would have to hear his testimony so as to assess his demeanor, know what evidence is available to corroborate his testimony, and perhaps even look at the impeaching evidence that the opponent plans to introduce. Rule 403 presupposes that the judge can determine the admissibility by assessing logical inferences at the time it is offered. If the judge were to assess credibility as well, it is difficult to see how this could be done without first hearing nearly the entire trial.’” Id., at 382.
Against this legal backdrop, an en banc court in Webb v. State, 36 S.W.3d 164 (Tex.App-Houston [14th Dist.] 2000) confronted the extraneous offense issue in an aggravated sexual assault case involving a topless dancer. Id., at 171. During the trial, the State introduced the testimony of another topless dancer who testified that the defendant sexually assaulted in a manner similar to the crime charged. The defendant challenged the issue on appeal:
“Porter, another topless dancer who worked at the same nightclub as Baird, testified that the appellant sexually assaulted her in much the same way he was accused of sexually assaulting Baird. In describing the events leading up to her attack, Porter testified that the appellant offered her a ride home from the nightclub after she became intoxicated. According to Porter, the appellant took her to his home and told her she should sleep there for a few hours before going home to her son; after she fell asleep, the appellant got on top of her and began choking her. Porter testified that the appellant then commanded her to have oral and vaginal sex with him. She did.” Id., at 180.
Relying upon an aggravated sexual assault of a child case that dealt with the extraneous offense issue, the appeals court held that the trial court committed reversible error by allowing Porter’s testimony:
“In Owens[v. State, 827 S.W.2d 911, 914 (Tex.Crim.App. 1992)], the only ultimate fact in dispute was whether the appellant committed the charged offense, i.e., aggravated sexual assault of a child. There was no dispute as to identity, motive, intent or any of the other exceptions listed in rule 404(b). The jury had the testimony of the appellant and the complainant, appellant’s daughter; the State then produced another of the appellant’s daughters as a rebuttal witness after the appellant denied the offense occurred. The Court of Criminal Appeals held that evidence of an extraneous offense tending to show the appellant’s ‘system’ could not assist the jury in its determination of whether or not the appellant molested the complainant except by showing character conformity in violation of rule 404(b).
”Likewise, the ultimate fact in dispute here is whether the appellant committed aggravated sexual assault of Baird. At trial, the court ruled that the extraneous offense evidence involving Porter would be admitted because it was a ‘signature type’ offense that showed ‘opportunity, plan, maybe motive, scheme . . . .’ However, there was no dispute as to identity, motive, intent or any of the other exceptions listed in rule 404(b). The State produced Porter in its case in chief for the stated purpose of challenging the ‘defensive theory’ brought out in the cross examination of Baird that she was mistaken or unsure about the events that occurred because of her high level of intoxication on the evening in question, i.e., to show the offense did not occur. Evidence of an extraneous offense against Porter in April or May of 1995, could not assist the jury in its determination of whether the appellant sexually assaulted Baird in August of 1996, except by showing character conformity in violation of rule 404(b). In other words, proof of the sexual assault against Porter served no probative function other than to show appellant as a person who commits sexual assaults in general, and, therefore, was more likely to have committed the sexual assault against Baird, an inference rule 404(b) strictly forbids.
”On this record, we cannot find that the assault on Porter had any true relevance apart from the appellant’s character or his actions in conformity therewith. Rule 404(b) proscribes the admission of such evidence. Because the trial court failed to identify any legitimate reason for allowing evidence of this extraneous offense and our independent review of the record reveals none, we find it was an abuse of discretion for the trial court to admit evidence of it.” Id., at 190-81.
After the en banc Webb decision was handed down, the court of criminal appeals qualified its per se 404(b) exclusion of extraneous offense evidence when offered as conformity of the defendant’s character by saying that such evidence can be presented in rebuttal to certain defenses raised by a defendant.
First, in Powell v. State, 63 S.W.3d 435 (Tex.Crim.App. 2001) the defendant in child indecency case asserted a “lack-of-opportunity” defense in both his opening statement and during the cross examination of the child complainant. Id., at 439. The court said the trial court did not err by allowing the state to present evidence of extraneous offenses to rebut the defense of lack of opportunity. Id., at 438.
Second, in Wheeler v. State, 67 S.W.3d 879 (Tex.Crim.App. 2002) the defendant in a child sexual assault case asserted two defenses: lack-of-opportunity and frame-up. The court said the trial court did not err by allowing evidence of extraneous offenses to rebut the “frame up” theory because the extraneous misconduct was similar to the charged conduct. Id., at 887.
Third, in Moses v. State, 105 S.W.3d 622 (Tex.Crim.App. 2003) the defendant in a public bribery case involving a police officer asserted two retaliation defenses. First, the defendant alleged that the criminal charge was brought against him because his wife had complained about other police officers violating a tow-truck policy, and, second, the criminal charge was not filed against him until after his wife made the charges against the other officers. Id., at 627. The court said the trial court did not err by allowing evidence of extraneous offenses to rebut the retaliation defenses.
It should be pointed out that the court of appeals in Bass v. State, 222 S.W.3d 571 (Tex.App.-Houston [14th] 2007) last year followed its en banc precedent in Webb against the State’s argument that Powell, Wheeler, and Moses undermined the precedential value of Webb. Id., 576-77. The Bass court – confronting a sexual assault case involving belated sexual assault allegations made by an adult female against a former pastor for sexual abuse when she was sixteen – ruled that a “fabrication” defense was distinguishable from the defenses raised in Powell, Wheeler, and Moses. The court found reversible error because the trial court admitted extraneous offenses demonstrating conduct similar to the conduct charged. Id., at 578.
More recently, however, the court of appeals seem to qualify Webb and Bass in State v. Bargas, 252 S.W.3d 879 (Tex.App.-Houston [14th] 2008). The Bargas court held that the use of extraneous offense evidence could be used in a “fabrication” defense case when that defense is laced with a retaliatory motive. Id., at 893-94. The defense in Bargas – another aggravated sexual assault of a child case – presented the defense that the child victim fabricated the sexual assault allegations in retaliation for her step-father’s temper and physical abuse. Id. at 893. While the Bargas court agreed with the Bass ruling that evidence of extraneous offense evidence is inadmissible in rebuttal to a straight fabrication defense, this evidence is admissible when a fabrication defense is mixed with another underlying defense theory. Id., at 891, FN 9.
Bargas has a chilling effect on a fabrication defense. The defendant cannot be realistically be put on the witness stand in support of the defense because he may inadvertently say something indicating lack-of-opportunity, retaliation, or some other motive for the child victim’s fabricated sexual assault allegation and this would open the door to rebuttal evidence involving extraneous offenses or prior bad acts. Bargas also limits the line of questioning of jurors on voir dire by defense and restricts what defense counsel may say in his/her opening statement because of the need for caution against raising any other defense theory outside the issue of fabrication.
In effect, a fabrication defense cannot meaningfully be developed with evidence supporting the defense, i.e., lack of opportunity or retaliatory motive. It must be established on cross-examination of state witnesses, particularly the victim. The jury must be convinced that the victim’s testimony is not credible, not worthy of belief. That is a Mount Everest-like hurdle, particularly in child sexual assault cases. It demands of thorough examination of all offense reports, an investigation into the victim’s background, and a complete fact-check of all the circumstances associated with the charged offense long before the actual trial begins. This background information is critical to a structured cross-examination of a sexual assault victim, especially when that victim is a child.
In their San Antonio presentation, attorney Schneider and Dr. Blotcky addressed what they called the “structure of the cross-examination” of a child sexual assault victim:
“Two concepts to consider in designing cross-examination of a child are reality monitoring and source monitoring…
Open-ended explanation with the child that leads to bizarre, unrealistic or impossible stories suggests either he’s reporting a fantasy or he’s defensively expressing his terror. An obvious example here would be that the child beat up the predator and threw him out the window.
Source monitoring is also a rich area for exploring validity. Reality monitoring refers to distinguishing if the event was real or imagined. Source monitoring looks to the origin of the information that the event actually occurred. Was the child told it occurred by his friends, by his parent, by C.P.S. or a detective? Often children have been told by a number of these people whether directly or by indirect positive reinforcement. And the story once told, children’s accounts are often reinforced and shaped to fit the picture. Some children are repeatedly told not to change their story in any detail because they will no longer be believed “even if they recall something small and change their mind about what happened, they should stay with the exact same story.”
Another illustration of this in daily life is a child’s recanting a story in a book or from a favorite movie as if it had actually occurred. These errors of “reality” and “source” fall under what we would classify as genuine. The child needs help in gradually working his way to distinguish reality for you. And this must be done patiently and using a nonthreatening style what you refer to as disarming.
Source and reality monitoring can be explored through a series of questions, e.g., : Tell me about what you like to do? Whom does that with you? What do you do with your mom? Tell me all about it? What do you do with your dad? Tell me what you do at school. Tell me about your teacher. So when you are alone with dad, do you remember feeling his hand touch your privates? Did someone tell you he touched your privates? If you remember him touching your privates, can you remember where you were? Who else was there? What happened next? And then what? How many times did he touch your privates? Can you tell us whether you remembered it happening first or did you hear about it from someone first? Are you ever confused about whether your mother told you or whether you actually remember it? Do you ever think it was someone else? How do you know it was your dad (teacher, etc.)?
Now some of these are hypothesis challenging and suggestive, but after the child has made the allegation and testified to it, you need to look for another hypothesis or explanation to confirm the child’s accurate recall and testimony or to impeach it. Henderson in (Westcott, H., Davies, G., and Bull, H. (2002) in their handbook Children’s Testimony outline the reasons children lie. Of particular interest, however, is the discussion of cross-examination. Studies reveal that lawyers tend to believe children were capable of remembering events accurately and being reliable witnesses and believed that false allegations of sexual abuse were rare (p. 280). Further, they had little idea of the possible causes of false allegations or the power of suggestion and therefore were not well equipped at mounting a defense. Attorneys were hesitant to use the age-appropriate language of the child. They also vastly underestimate the high proportion of cross-examination questions the child misunderstands.
Manuals suggest direct examination be in chronological and logical order to help the comprehension and retention of evidence and advise cross-examiners change subjects rapidly to confuse dishonest witnesses. Much of cross-examination theory she holds is in the effort of persuasion rather investigation and emphasizes controlling the witness’ disclosures. She[Henderson] reports that children are often cross-examined with the same goal. Direct examination is used not as investigatory, but as simply an organizer for the witness to retell his story. Cross-examination is not investigatory, it is intended to break down the story told, reshape it, or discredit the witness. Child witnesses are treated similarly and the power of suggestion is even greater with them.
The attorney’s attitude toward the child must be accepting warm and even calming. His attitude about the child’s version of his testimony can be incredulous and conveyed in his tone of voice suggesting to the child he should search for another version more pleasing to the cross-examining attorney. Cross-examination breaks most of the rules of a forensic psychiatric evaluation. Indeed, I suspect you would use most of the errors of a forensic evaluation in order to manipulate the testimony on cross, e.g., suggestion, leading, asking if the child would like to rethink his answer or response about a certain piece of testimony, etc. But, remember the cross-examining defense attorney is speaking to the court as well as the child. The jury to some extent will respond to your examination and factor that into their evaluation of the child’s credibility. Jurors remain generally sympathetic to child witnesses and attorneys must be sympathetic as well. Remember, the child witness-whether confused, honest or purposefully deceitful – is stressed, conflicted, frightened, and guilt ridden and needs your compassion.
The cross of the child, like any other witness, should have a beginning, a middle and a strong ending. Based on your investigation and preparation and defenses, an outline of your cross can include the following:
1. Beginning:
Make the child talk. You are a stranger and probably have never met the child or talked to the child. Find a topic that will allow the child to relax.
2. Identify who the child is:
Determine the physical abilities of the child.
What is the educational level of the child?
What is the child=s personality?
3. Identify the child’s living environment:
a. Typical day of the child.
b. Type of housing for the child.
c. Who does the child depend on?
d. How many children or adults are in the home?
4. If relevant, identify the basis for the child knowledge of sex.
5. Determine the origins of the child’s story.
6. Identify stressors in child’s life.
7. Identify rewards for disclosing abuse.
8. Watch for key prosecution phrases repeated in rote fashion by the child.
9. Explore the child’s feelings for role players in the case and the strength of the child’s feelings toward them.
10. Show the attention given to the child because he is a witness.
11. The allegations:
a. never repeat the abuse.
b. bring out physical impossibilities.
c. bring out prior inconsistent statements.
d. reveal differences between other child witnesses.
e. demonstrate vulnerability to suggestion.
12. End on a strong note that leaves the jury with a positive feeling towards you.
During a cross of a 4-year-old boy, I asked if he had ever seen a teddy bear that I pulled from a box at my feet. He asked to hold it. We talked about it. Then he wanted to take a nap with the teddy. The child denied ever seeing the bear. Later, I showed the jury a picture of the teddy bear in the child’s bedroom in my client’s house.” (Cross-Examination of Child Witnesses, presented at the 19th Annual Rusty Duncan Advanced Criminal Law Short Course in San Antonio,
Texas (June 15-17, 2006), Houston criminal defense attorney Stanley G. Schneider and Dallas doctor Mark Blotcky)
It is within the parameters of this kind of structured of cross-examination, like that described by Schneider andBlotcky, that the defense of fabrication is won or lost. Of course, each case is different and the cross-examination will have to be modified to suit the particular facts of each case. But the essential key to establishing a fabrication defense is through structured cross-examination. Carefully crafted open ended questions used to solicit details the prosecutor avoided, along with leading questions to assist in the truthful presentation of events are crucial. An attorney can only prepare such a cross if they are completely familiar with the facts of the case and truly prepared for trial. This requires preparation, and more preparation, by defense counsel.
But the rewards are tremendous. An innocent person will not be wrongfully convicted and have his/her life destroyed by a fabricated sexual assault allegation.
Take the first step toward protecting your freedom by contacting us now
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It was a pleasure speaking with John. He is knowledgeable and has a true desire to help the people of society. I turned to him for some guidance of a long-standing issue. He never … More rushed our conversation and went out of his way to look into the details to provide the right answer as well as assist me anyway he could. Thank you for our conversations and I wish your and your firm the best. If you need a lawyer, John Floyd is your guy!
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John represented me in court for roughly 2 years. I won't (and shouldn't) get into any serious details, but let me tell you that I couldn't have chosen anyone better. … More Seriously.Every appearance in court I felt very comfortable. The judge and DA's had a high regard for his reputation. There is a time I recall where simply his presence greatly impacted the court's interpretation of my case and persons. We were in front of the stand and the judge could not stop talking about John's prestige and past accomplishments and how that took in relation to my case. I kept silent in front of the judge, but I observed then that John's popularity and reputation within the court had already given me a better looking rapport with the judge. Let me tell you, I never had more confidence then, knowing that the judge held him in such high regard.This is not to mention how personable John is. I'll be honest that during the stress of court, sharing a laugh with your lawyer helps a lot. This may sound a lot, but I really appreciated the relationship we had then. This is also not to mention that he was able to deal very well with any DA that rotated over the years. Seriously, John was great, prompt with information and very hands on with my case. I had great peace those 2 years until everything wrapped up.If you're looking for a lawyer, I highly, HIGHLY recommend the John T. Floyd Law Firm. He IS nationally renowned, you know. He'll get the job done to the utmost confidence. He's very experienced and has a great record to boot. I am glad to have had him represent me in court and trust me that I never thought I'd ever say that (and whoever does?). We explored every avenue of victory together and I personally enjoyed the experience, despite the seriousness of the accusation.If you have a case that needs to be represented at the highest levels, choose John T. Floyd. He's a good man and very good at what he does. Him and his team has the experience you need to make the best decisions and options to get the best outcome for your case. We got the best result I could possibly ask for, thank God.Seriously. Hire John. He knows what he's doing.Seriously.
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One of the few honest lawyers I have ever talked to. His complimentary consultation was knowledgeable and thorough. He knew exactly what the issue was and how to handle it. His candid … More appraisal of the situation and how to proceed saved me thousands of dollars in legal fees. If you have a case requiring expertise in John's area of practice, look no further. Hire this man!
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I had the opportunity to read an article that Mr. Floyd wrote and it was very interesting. I called him about the article and advice concerning a similar situation. He not only gave … More me excellent advice, he pointed out not just what I wanted to hear but what I needed to hear concerning my situation. The Good, The Bad and The ugly in a manner or speaking. He spoke with an open and honest heart with information to help me and not just to get a client.
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If you are in trouble and need a lawyer, contact the John T. Floyd law firm. Some of the best lawyers in Texas work there! Understanding and helpful lawyers and staff that will do all … More they can to help you 😊
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He gave me one of the most honest answers I have received in a very long time about any issue I was having with anything. Legal or not legal. I highly recommend giving him a call and … More will be referring him to friends and family if they have any issues in the future.Positive
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He took time out of his day to answer my legal questions and didn’t even charge me. I would definitely recommend him to you.
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Gave free consultation on getting gun rights back. He truly cares about gun rights and getting you the help you deserve. 100% worth a callPositive
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Very professional, great quality work, and very friendly and helpful. Overall, their service is phenomenal. I recommend Mr. Floyd to anyone.
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Mr. Floyd took the time to explain his experience with the law to me in layman's terms. Definitely give him a call.Positive
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He was honest , knowledgeable , and professional about what we talked about. Most lawyers are just about the money , but not john.Positive
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He was very truthful and honest with us very great man I would recommend him and we would use him again
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Very professional honest and works hard currently working my husband’s appeal I pray he does his best workPositive
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I contacted John T. Floyd Law firm and I was very satisfied with service extremely helpful and friendly thank you Mr. FloydPositive
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This law frim was informative,great response time ,and the attorney called back not some secretary or legal assistant thank u guys for all your help wish it was more like youPositive … More
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I would highly recommend Mr Floyd. He was very helpful and knowledge with a legal question I had.Positive
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He explained my case better then any other lawyerPositive
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Very informative
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Had the pleasure speaking with John Floyd on a personal matter, he was very responsive, nothing but exceptional, and he really cares about you with sincerity and most importantly knows … More what is he talking about! No games or bs, his approach to my situation even though I knew it was probably way smaller then what he normally takes on, he was extremely helpful and didn't care about the size of the matter like other attorneys do. He really looked out for my best interests. You can tell he has decades of experience doing what he does just by chatting with him. I would highly recommend him.
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Words can’t describe how grateful I am for working with John, he went above and beyond my expectation. I was wrongly accused and hired many lawyers before hiring John Floyd but they … More all disappointed me, I had lost hope until a friend of mine referred me to John. From the start he had my best interest in mind and gave helpful advice, he explained the process and guided me. He put more work and time than all my previous lawyers that cost me thousands of dollars. He was constantly communicating with court and defended me more than all lawyer i had hired before him. Don’t waste your time and money like I did, believe me when I say I hired countless lawyers before him and no one came close to John. I’m forever thankful for him for fighting for my innocence and getting my case dismissed. Thank you so much🙏🏼🙏🏼
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I called Mr Floyd and left a message, with in the hour I received a call back with much more information then I could have ever expected. Mr Floyd was very informative on every question … More I had for him. He seemed like he cared, instead of like most attorneys that you talk to that are just out for a quick buck. If you want someone that is going to shoot strait with you, and has your best interest in hand, this is you guy. This was the best experience that I have ever had with an lawyer.
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I can state with confidence that Mr. Floyd and his team are the most competent and professional lawyers one can hope for. My case was quite complex and I admit that as a law student … More I was not the most patient client. Mr. Floyd did a phenomenal job of managing the bench, prosecution and myself! The result was above expectation, and I will never hesitate to recommend this firm regardless of the caliber of the case at issue.
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It was a pleasure working with Mr. Floyd. I contacted him regarding a legal matter and he was extremely knowledgeable about the law, and responded in a timely manner. I appreciated … More the fact I did not feel rushed, and he made sure he thoroughly answered all questions I had. I would highly recommend him!Positive
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Spoke with John Floyd about a 45 year old criminal case I was involved in. I had very little information about the case and John helped me search what records were available and gave … More me guidance to find more information. He was very professional and took his time helping me. I may need to hire a lawyer on this case and Mr. Floyd will be the man.Thanks John.
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Very professional and straight forward. He's not going to waste your time or money. Very knowledgeable in a large range of possible matters one could face living in these days … More and times. If ever you need legal assistance, this is who I would suggest. Awesome!Positive
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I called about some legal questions I needed to get clarified and John was able to give me clarification and sound advice. I will definitely contact John for all future legal questions … More and issues.Thank you John!Positive
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Knows his stuff and well respected with DA and judges. I have referred him a couple times and every client has been satisfied
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John is beyond knowledgeable! If I decide to pursue my case any further I would only have him represent me.
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What a great attorney, this guy really took time out of his day to answer my questions and explain my case to me. Very grateful, thank you so muchPositive
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Absolutely a very professional lawyer. Very well read in the current law and more than willing to help if needed.
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Mr. John he’s a professional he knows what he’s doing and he’s patient they recommend Him stronglyPositive
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Great service, very knowledgable and happy to help with any questions I had
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Quick to action and helpful and knowledgeable with entertainment industry based issues!
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Responded on a holiday week. Very knowledgeable and reassuring.
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Very professional
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I want to thank John T. Floyd and all of his team. He is the best lawyer who cares aboutHis clients and fights really hard to get the best outcome. He is a fighter and he is awesome!!!I … More recommend if any one needs criminal defense , he is the BEST. We had a really serious caseAnd we are very thankful for the outcome. Thank you John!!!!! God bless you!!!!!!
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The attorneys at John T. Floyd Law Firm work diligently to achieve the best possible results for their clients. They are caring and knowledgeable professionals. Their expertise in the … More law and their experience as trial attorneys makes them the right choice as a defense attorney. I recommend this law firm highly.
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From beginning to end this firm handled my case like the top tier professionals they are. I would not trust ANYONE else with my legal needs after having less than stellar experiences … More with other teams. Thank you Floyd!!!
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I really felt like the team cared about my case and am super satisfied with the outcome. Would not recommend anyone else!
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These guys do amazing work and have phenomenal service! Hands down best in the Houston area!!
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John and Chris are true professionals! Love those guys like family!
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Mr. Floyd and his team are very knowledgeable, informative, and helpful.
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A team you can depend on to stand up and fight for you to prove the truth the whole truth!
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Mr. John T. Floyd represented me.I couldn't be happier with the outcome he managed to achieve on an VERY Important case that was dismissed the day of Trial. He is patient & … More very knowledgeable of the legal system. I HIGHLY recommend him to anyone in need of a lawyer!John, I am forever grateful & satisfied with the effort you put forth & all you did for me. Thank you isn't enough!God bless you & your family!
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The John T. Floyd Law Firm assisted me, and I can tell you that the attorney took the time to answer my questions, and I didn't feel rushed or dismissed as I have experienced in … More the past with attorneys. The attorney was very nice and extremely knowledgeable. Initial impressions and continued excellent customer service are big factors for me and as such I would highly recommend this firm.
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I thank you for your efforts to help Felons regain their Civil rights, and for the information on possession , I am A convicted Felon, no violent history. I am an expert shot, I am … More 76 yoa, and very concerned about the present lake of Security in our State and Country. God Bless and Prosper you in your efforts, Your friend, Sonny Bivens
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I really appreciated both Chris and John helping with my legal questions and concerns. Both are good guys and I would not hesitate to recommend them.
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Extremely helpful!!! Helping me understand the law.
John T. Floyd is Board Certified in Criminal Law By the Texas Board of Legal Specialization
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