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THE DIFFICULTY WITH CRIMINAL EVIDENCE

Oct 02 2012
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Rule 403: Courts Should View Child Porn if Defense Moves to Exclude as Unfairly Prejudicial…
By: Houston Criminal Lawyer John Floyd and Paralegal Billy Sinclair

Jurors in criminal trial are sometimes called upon to view difficult, disturbing pieces of evidence. This is particularly so in cases of violence and sex offenses, especially child pornography cases. In fact, it is probably easier for jurors to view photographs and/or videos depicting images of the aftermath of a violent offense than it is to view photographs and/or videos of child pornography. Many times, when the question of whether the images are in fact child pornography is not in issue, the Government and criminal defense attorney will stipulate to the jury that evidence is in fact child pornography. In those cases where neither party wants to proceed on the basis of a stipulation, the Government must allow the defense to inspect the evidence it plans to offer into evidence so the defense lawyer can prepare a proper defense. This process provides defense counsel with graphic details of the child pornography the Government will rely upon to make its case. These details often inform defense counsel of the level of prejudice the images/videos of children being sexually exposed and/or assaulted will have on the jury.

What is the criminal defense lawyer to do? The U.S. Third Court of Appeals on September 18, 2012 offered strong suggestions on this question in United States v. Cunningham. The Third Circuit joined the Ninth and Seventh Circuits in adopting the evidentiary procedure that should be utilized by the Federal district courts in dealing with the admission of such highly prejudicial evidence.

In September 2010, David L. Cunningham was sentenced to 210 months in prison and an additional 20 years of supervised release by U.S. District Court Judge Arthur J. Schwab following Cunningham’s conviction for the receipt, possession and distribution of child pornography. At Cunningham’s trial, conducted in the Western District of Pennsylvania, Judge Schwab allowed the Government, over the objection of Cunningham’s defense counsel (Office of the Federal Public Defender), to show the jury two videos containing seven clips depicting samples of the child pornography possessed by Cunningham. The seven clips totaled two minutes. The images depicted were extremely graphic and surely caused the jurors to have tremendous prejudice against Cunningham.

Cunningham was arrested in June 2007 in connection with an undercover online investigation conducted by the Pennsylvania State Police into “peer-to-peer file sharing networks.” These file sharing networks allow individuals to share data contained in each other’s computer files, including child pornography. As part of its investigation, State Police investigators downloaded six movies depicting “prepubescent children engaging in sexual activity.” Investigators promptly obtained a court order to identity the IP address that had shared the files containing the movies. That IP address led investigators to a computer at a residence shared by Cunningham and his two siblings. They obtained a search warrant for the residence where they seized a computer from Cunningham’s bedroom. A preliminary review of the computer’s hard drive revealed that 36 of its 212 shared files contained child pornography. Cunningham admitted that 20 to 30 percent of the material on his computer was child pornography. A subsequent “forensic analysis” revealed that 46 of the computer’s 212 shared files contained child pornography.

Prior to trial, Cunningham’s attorney filed a Motion in Limine Concerning Pornographic Images and File Names under Federal Rule of Evidence 403 requesting that the trial court prohibit the Government from showing any of the child pornography videos obtained from Cunningham’s computer. Rule 403 requires the trial court to conduct a balancing test to determine if evidence has “probative value” or “is substantially outweighed by the danger of one or the more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.”

The Rule 403 motion triggered a contentious debate between defense counsel and Judge Schwab who apparently had an ongoing strained relationship with the Federal public defender’s office. Cunningham’s attorney informed Judge Schwab that she was “stipulating that the government exhibits constituted child pornography.” The judge nonetheless denied the motion, allowing the Government to publish “representative samples of the Child Pornography instead of the entire ‘collections,’ as well as the names of the various files in the ‘collection.’” As for the defense counsel’s stipulation, Judge Schwab said “the parties may (but are not required to) stipulate that the child pornography evidence constitutes child pornography for the purposes of the Indictment.” Pursuant to the court’s directive, the Government and defense counsel agreed to the following stipulation:

“[T]hat the video files obtained from IP address 71.206.239.202 on June 19, 2007, constitute visual depictions of real children under the age of 18 engaging in sexually explicit content. The parties further stipulate and agree that the video files recovered from [Cunningham’s] computer on July 17, 2007, constitute visual depictions of real children under the age of 18 years of age engaging in sexually explicit conduct.”

Subsequent to this stipulation, the Government provided defense counsel with access to the “video clips” it planned to introduce at trial. In response, defense counsel filed a Motion to Limit Evidence of Child Pornography. The motion contained graphic descriptions of the video excerpts the Government planned to show the jury. (While most appellate court decisions dealing child prosecutions try to avoid subjecting “the reader to the graphic and disturbing details of the pornography,” the Third Circuit felt it had to recite the descriptions used in defense counsel’s motion to understand “the character of the issues” confronting the court.)

We reluctantly agree, and will recite the motion’s descriptions of the child pornography in question, but we cannot, in good conscience, recite the “more graphic detail[s]” of the child pornography evidence described by the Third Circuit in the body of its opinion.

Defense counsel’s motion described the Government proposed excerpts as follows:

“These clips include graphic and haunting images of child pornography. Specifically, they include a close up of an adult woman licking a very young female child’s genitalia – so young, in fact, the child appears to be a toddler; videos of penetration; several videos depicting children tied up and/or blindfolded, including images where a young, prepubescent girl was penetrated by an adult male while her ankles and wrists appeared to be bound to a table. Several videos showed the faces of the children. In every image where a face is shown, the body (specifically, breasts, genitalia, and lack of pubic hair) clearly, and unequivocally, proves that the image portrays a child. In one, a young girl is seen performing oral sex on an adult male, who ejaculates on her face, which is openly displayed for the camera.”

When arguing before the court about the admissibility of this evidence, the Government conveniently failed to provide Judge Schwab with a description of the video excerpts it proposed to use. Defense counsel was forced to provide Judge Schwab with the aforementioned descriptions, calling the depictions “obscene, violent, and humiliating, necessarily conjuring feelings of disgust and blind rage.” Defense counsel suggested that if the court was inclined to allow this horrific evidence, it should limit the evidence in four ways: 1) only still images of any video should be shown; 2) no images, whether still or part of a video, should display bondage or actual violence, including the penetration of prepubescent children by adults; 3) no audio should accompany any of the videos; and 4) the faces of any minors should be obscured from all images.

In response to the motion, the Government agreed not to use audio in the excerpts, but strenuously objected to the other three limitations proposed by defense counsel as an effort “to sanitize, distort and mitigate the force of evidence that constitutes the very evidence of the offenses charged.” The Government argued that even with a stipulation, it still bore the “extremely high burden” to prove that Cunningham “knowinglydistributed, received and possessed these images; thathewasawareof their character as child pornography; [and] that he was aware that images depictedrealminors engaging insexuallyexplicit conduct.”

We find the Government’s argument disingenuous. First, State Police investigators could have established the knowing intent to receive, possess, and distribute child pornography by testifying about the details of their investigations and Cunningham’s damming confession, in which he admitted searching for and viewing child pornography. In addition, Cunningham offered to stipulate that the evidence was child pornography thereby agreeing that the jury would be instructed that the images were in fact child pornography; the stipulation also expressly conceded that the images depicted minors (anyone under 18 years of age) engaged in “sexually explicit conduct.” With the investigator’s testimony regarding the background investigation, along with Cunningham’s admissions, the Government essentially had the proverbial “open and shut” case. But for whatever reason, it wanted jurors to view the horrible images of child pornography detailed in defense counsel’s motion to exclude.

The Government tried to justify its position by saying the jury should be allowed to see the horrific images so it could “fully appreciate the nature of child pornography crimes, which necessitates consideration of the images themselves.” That’s utter nonsense. The crime of child pornography was not on trial; Cunningham was on trial for receiving, possessing, and distributing child pornography. The Government did not bear any burden to educate the jury about the “nature of child pornography.” The term itself speaks to the “nature” of the offense. Thus, the Government’s only burden was to convince the jury beyond a reasonable doubt that Cunningham received, possessed and distributed child pornography. Federal juries do not impose, or even influence, sentencing; thus, the Government had no legitimate interest in provoking “blind rage” in the jury to secure a stiff prison sentence.

The Government’s absurd argument was sufficient for Judge Schwab. He denied defense counsel’s motion to exclude with the condition that the Government not use audio with the videos. Significantly, Judge Schwab allowed the highly prejudicial evidence without conducting a Rule 403 balancing analysis. This omission did not sit well with defense counsel who informed the judge during the last pre-trial conference held in April 2008 that it planned to motion for reconsideration of the video excerpts’ admissibility with a specific request that Judge Schwab personally review the excerpts prior to ruling. The judge was not impressed, immediately denying the motion, informing counsel that she had “had plenty of time to file motion after motion, which [counsel had] done.” Revealing his frustration with defense counsel’s tactics, Judge Schwab chastised counsel by telling her that the court had “ruled again and again and again”; and was “sorry” counsel did not “like it; but the court would not allow counsel to “come in every day and give us another snapshot and more motions, and next day another snapshot and more motions.” Although frustrated, Judge Schwab gave counsel until 4:00 p.m. that day to file its stated motion.

Defense counsel complied with Judge Schwab’s directive. In this motion, defense counsel asserted that “someone else” had downloaded the videos in question, and in addition to his stipulation, Cunningham agreed that “whoever possessed, received and distributed those images would know that they depicted real children engaging in sexually explicit activity.” Defense counsel, therefore, posited there was “little value in presenting the video excerpts,” especially considering “the uniqueness and significance of this type of contraband.” Defense counsel concluded her motion with a request that the video excerpts either be declared inadmissible or subject to further limitations. The motion also closed with a request that Judge Schwab “view the video excerpts prior to making a ruling on their admissibility.”

Four days later Judge Schwab denied defense counsel’s motion, saying that she had cited “no case precedent for its proposition that the child pornography must be viewed by the Court or that it is a necessary exercise of the Court’s discretion to do so.” Judge Schwab added that the “descriptions [of the video excerpts] [were] sufficient for [him] to rule [on the past and pending motions], since the descriptions [were] quite telling of the images and their graphic nature.”

The case then proceeded to trial, and as anticipated by defense counsel, “several jurors” on voir dire responded they would “have difficulty being impartial” and had to be excused. When informed that the video excerpts would show children under eight, one juror in a sidebar with the judge stated it would be difficult to be impartial and another said she would be distressed by “portrayals of children as young as toddlers being molested.” Both were also excused.

The Third Circuit then described the video excerpts in complete detail—something we elect not to do here. Suffice it to say that the excerpts would put almost any juror in a state of “blind rage” against the defendant. On appeal, the Third Circuit addressed the primary issue associated with the admission of the excerpts—that Judge Schwab should have viewed the excerpts prior to allowing them into evidence. The Government justified this judicial omission, telling the appeals court that Judge Schwab had “no duty to view the video excerpts because [he] understood the content and character of the excerpts … from the summary that Cunningham had provided to the [judge].”

While announcing that “the question presented for resolution has seldom been addressed,” the Third Circuit found that Judge Schwab should have indeed viewed the video excerpts under Rule 403 prior to allowing them in evidence. The appeals court secured guidance from a 2007en bancdecision by the Ninth Circuit in United States v. Curtin and a 2011 decision by the Seventh Circuit in United States v. Loughry to reach its conclusion that Cunningham’s conviction should be reversed.

“In sum, we find bothCurtinandLoughrypersuasive. We agree that a district court should know what the challenged evidence actually is – as opposed to what one side or the other says it is – ‘in order for [the court’s] weighing discretion to be properly exercised and entitled to deference on appeal.’ We also agree that there may be instances where a district court can properly decline to view challenged evidence when it is obvious to the court that the danger of unfair prejudice from such evidence substantially outweighs any probative value that it might have.

“Thus, we conclude that, speaking generally, a district court should personally examine challenged evidence before deciding to admit under Rule 403. However, asLoughryreflects, while that is the best course (‘The safest course, however, is for the court to review contested evidence for itself’), it may be that, when a court has been provided with a sufficiently detailed description of the challenged evidence, it need not undertake that further review. In other words, if, after reviewing a detailed description of the evidence, it is obvious to the court that the probative value of the evidence is so minimal that it is substantially outweighed by the danger of unfair prejudice, a court need not personally examine it. This ought not be seen as an invitation to freely deny the admission of evidence that no one of ordinary sensibilities would want to review. Any such approach would, of course, be out of keeping with the district court’s obligation, however uncomfortable, to weigh the potential probative and prejudicial impact of evidence, while considering the legitimate interests of both the prosecution and the defense.

“The video excerpts here included ‘the kind of highly reprehensible and offensive content that might lead a jury to convict because it thinks the defendant is a bad person and deserves punishment, regardless of whether the defendant committed the crime charged.’ Although we accord district courts broad discretion in making a Rule 403 determination, that discretion is not unfettered. ‘The hackneyed expression, ‘one picture is worth a thousand words’ fails to convey adequately the comparison between the impact of the … portrayal of actual event upon the viewer of the videotape and that of the spoken or written word upon the listener or reader.’ The District Court’s refusal to here to view the video excerpts to assess their prejudicial impact and instead, over objection, rely on written descriptions prior to admitting them, was ‘arbitrary … [and] unreasonable.’”

While we wholeheartedly agree with the Third Circuit, we would take it step further. A district judge shouldalwaysbe required to personally view challenged evidence. That is why the judge is the judge. He or she is the arbiter of what evidence to admit in a criminal trial. Evidence is sometimes difficult to view as crimes are sometimes difficult to comprehend, but anytime a judge is prepared to let a jury view a piece of evidence, she should be prepared to view that evidence before the jury does. In this case Judge Schwab had an obvious problem with the way the Federal public defender was representing her client. This was evidenced by the judge’s sarcastic comments prior to the trial and afterwards when Judge Schwab voluntarily recused himself while the case, thus preventing the Third Circuit from having to address the issue on appeal. Thus, enormous resources were expended – actually wasted – apparently because the Government was overzealous and the Judge intransient.

By: Houston Criminal Lawyer John Floyd and Paralegal Billy Sinclair
John Floyd is Board Certified in Criminal Law by the Texas Board of Specialization

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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!
  • Avatar Larry Green ★★★★★ 3 years ago
    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.
  • Avatar Jackie Cohen ★★★★★ 3 years ago
    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 😊
  • Avatar It’s Me ★★★★★ 3 years ago
    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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  • Avatar I’m Home ★★★★★ 3 years ago
    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.
  • Avatar Tad Nieschwietz ★★★★★ 3 years ago
    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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  • Avatar Maher Abbara ★★★★★ 3 years ago
    Very professional, great quality work, and very friendly and helpful. Overall, their service is phenomenal. I recommend Mr. Floyd to anyone.
  • Avatar Thomas McLaughlin ★★★★★ 3 years ago
    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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  • Avatar Zarrie Adkins ★★★★★ 3 years ago
    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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  • Avatar Keisha Gaches ★★★★★ 3 years ago
    He was very truthful and honest with us very great man I would recommend him and we would use him again
  • Avatar Samyra Carrasquillo ★★★★★ 3 years ago
    Very professional honest and works hard currently working my husband’s appeal I pray he does his best workPositive
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  • Avatar Raul Perez ★★★★★ 3 years ago
    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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  • Avatar Johnny Johnson Jr ★★★★★ 3 years ago
    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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  • Avatar Dana Adkison ★★★★★ 3 years ago
    I would highly recommend Mr Floyd. He was very helpful and knowledge with a legal question I had.Positive
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  • Avatar Crecencio Fabian ★★★★★ 3 years ago
    He explained my case better then any other lawyerPositive
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  • Avatar Barry Lewis ★★★★ 3 years ago
    Very informative
  • Avatar Ismael Flores ★★★★★ 3 years ago
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  • Avatar Neil Productions ★★★★★ 4 years ago
    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.
  • Avatar S A ★★★★★ 4 years ago
    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🙏🏼🙏🏼
  • Avatar Gary Watch ★★★★★ 4 years ago
    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.
  • Avatar Saman Daftarian ★★★★★ 4 years ago
    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.
  • Avatar calvin robinson ★★★★★ 4 years ago
    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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  • Avatar Alan Howk ★★★★★ 4 years ago
    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.
  • Avatar CMCustom Cycles ★★★★★ 4 years ago
    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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  • Avatar Greg Page ★★★★★ 4 years ago
    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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  • Avatar Kristen Rankin ★★★★★ 4 years ago
    Knows his stuff and well respected with DA and judges. I have referred him a couple times and every client has been satisfied
  • Avatar Kedar Puranik ★★★★★ 4 years ago
    John is beyond knowledgeable! If I decide to pursue my case any further I would only have him represent me.
  • Avatar Joseph Sivadon ★★★★★ 4 years ago
    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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  • Avatar Lex Strider ★★★★★ 4 years ago
    Absolutely a very professional lawyer. Very well read in the current law and more than willing to help if needed.
  • Avatar karim khalifa ★★★★★ 4 years ago
    Mr. John he’s a professional he knows what he’s doing and he’s patient they recommend Him stronglyPositive
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  • Avatar James Haggard ★★★★★ 4 years ago
    Great service, very knowledgable and happy to help with any questions I had
  • Avatar David Sustaita ★★★★★ 4 years ago
    Quick to action and helpful and knowledgeable with entertainment industry based issues!
  • Avatar Chad Groves ★★★★★ 4 years ago
    Responded on a holiday week. Very knowledgeable and reassuring.
  • Avatar Mark Fein ★★★★★ 4 years ago
    Very professional
  • Avatar Bthomason903 Bthomason903 ★★★★★ 4 years ago
  • Avatar Anton Jasser ★★★★★ 4 years ago
  • Avatar Alma Garza ★★★★★ 4 years ago
  • Avatar Victory 2020 ★★★★★ 6 years ago
    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!!!!!!
  • Avatar Alma Garcia Cunningham ★★★★★ 6 years ago
    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.
  • Avatar Rajiv Patel ★★★★★ 6 years ago
    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!!!
  • Avatar Jose Tapia ★★★★★ 6 years ago
    I really felt like the team cared about my case and am super satisfied with the outcome. Would not recommend anyone else!
  • Avatar Sagar Patel ★★★★★ 6 years ago
    These guys do amazing work and have phenomenal service! Hands down best in the Houston area!!
  • Avatar RAYNINN ★★★★★ 6 years ago
    John and Chris are true professionals! Love those guys like family!
  • Avatar Virginia Martin ★★★★★ 6 years ago
    Mr. Floyd and his team are very knowledgeable, informative, and helpful.
  • Avatar Darla Latham ★★★★★ 6 years ago
    A team you can depend on to stand up and fight for you to prove the truth the whole truth!
  • Avatar Veronica Elorza ★★★★★ 6 years ago
  • Avatar Karetta Lux ★★★★★ 7 years ago
    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!
  • Avatar GM ★★★★★ 8 years ago
    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.
  • Avatar Sandra Bivens ★★★★★ 8 years ago
    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
  • Avatar Mike Kittelson ★★★★★ 8 years ago
    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.
  • Avatar Robert Hair ★★★★★ 8 years ago
    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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