Ex Parte Giambi Boyd v. the State of Texas
CourtTexas Court of Appeals, 1st District (Houston)
Date FiledMay 28, 2026
Docket01-25-00682-CR
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
Opinion issued May 28, 2026
In The
Court of Appeals
For The
First District of Texas
————————————
NO. 01-25-00681-CR
NO. 01-25-00682-CR
NO. 01-25-00683-CR
———————————
EX PARTE GIAMBI BOYD
On Appeal from the 412th District Court
Brazoria County, Texas
Trial Court Case Nos. 100532-CR, 100541-CR, and 100542-CR
MEMORANDUM OPINION
This is an appeal from the trial court’s denial of a pretrial writ of habeas
corpus. Our opinion issued on March 19, 2026. During the pendency of the State’s
subsequent motions for rehearing and en banc reconsideration, the State informed
this Court that the issues presented in these appeals have become moot by Giambi
Boyd’s trial and conviction in the underlying cases. We agree.
After considering the State’s supplemental motion, we deny rehearing, but
withdraw our March 19, 2026 opinion and vacate our judgment of that date in each
cause.1 We substitute this opinion and accompanying judgment in each cause. We
dismiss the appeals as moot.
Background
Boyd was indicted for aggravated assault with a deadly weapon and two
offenses of murder.2 He filed an application in the trial court for a writ of habeas
corpus, seeking to reduce his pretrial bail. Boyd argued that he was entitled to his
requested relief because the State had failed to show that it was ready for trial within
90 days after his detention began, as required by Texas Code of Criminal Procedure
article 17.151.3 The trial court denied habeas relief. And Boyd appealed.4
1
The State’s motion for en banc reconsideration is dismissed as moot. See Ex parte
Baker, No. 01-22-00065-CR, 2023 WL 3311125, at *1 n.1 (Tex. App.—Houston
[1st Dist.] May 9, 2023, no pet.) (mem. op., not designated for publication); see also
In re Wagner, 560 S.W.3d 311, 312 (Tex. App.—Houston [1st Dist.] 2018, orig.
proceeding [mand. denied]) (“Because we issue a new opinion in connection with
the denial of rehearing, the motion for en banc reconsideration is rendered moot.”).
2
Trial court case number 100532-CR is appellate cause number 01-25-00681-CR.
Trial court case number 100541-CR is appellate cause number 01-25-00682-CR.
Trial court case number 100542-CR is appellate cause number 01-25-00683-CR.
3
See TEX. CODE CRIM. PROC. art. 17.151.
4
See TEX. R. APP. P. 31.
2
On appeal, we held that the State failed to demonstrate that it complied with
its mandatory burden under article 17.151 to show readiness for trial. See Ex Parte
Boyd, No. 01-25-00681-CR, 2026 WL 771065, at *1 (Tex. App.—Houston [1st
Dist.] Mar. 19, 2026, no pet. h.) (mem. op., not designated for publication). And we
remanded for the trial court to set pretrial bail in accordance with the statute. Id.
Subsequently, the State filed motions for rehearing and for en banc
reconsideration. During their pendency, the State notified this Court that Boyd has
now been “tried on both murder charges, convicted of the lesser included offense of
aggravated robbery, and sentenced to 22 years in each case.” The State filed certified
copies of the judgments.5 And it argues that Boyd’s “habeas issues have become
moot.” The State notes that the aggravated-assault charge “is still outstanding.” But
it argues that Boyd is no longer entitled to pretrial bail because he is “now serving a
sentence of imprisonment for another offense.”
Law and Analysis
Courts lack subject-matter jurisdiction to decide moot controversies. See State
ex rel. Millsap v. Lozano, 692 S.W.2d 470, 480 (Tex. Crim. App. 1985). If a case
5
Boyd was originally indicted for aggravated assault in trial court case number
100532-CR and for murder in case numbers 100541-CR and 100542-CR. He was
subsequently reindicted in the murders and convicted of the lesser-included
aggravated robbery in case numbers 105337-CR and 105338-CR. The State then
dismissed case numbers 100541-CR and 100542-CR. As discussed below, trial
court case number 100532-CR remains pending in the trial court.
3
becomes moot, it must be dismissed. See In re Bonilla, 424 S.W.3d 528, 534 (Tex.
Crim. App. 2014).
A case becomes moot if events during its pendency make it impossible for a
court to grant the requested relief or to otherwise affect the parties’ rights or interests.
See Jack v. State, 149 S.W.3d 119, 123 n.10 (Tex. Crim. App. 2004). When “the
premise of a habeas corpus application is destroyed by subsequent developments,
the legal issues raised thereunder are rendered moot.” State v. Golding, 398 S.W.3d
745, 747 (Tex. App.—Houston [1st Dist.] 2011, pet. ref’d) (internal quotations
omitted); see Bennet v. State, 818 S.W.2d 199, 200 (Tex. App.—Houston [14th
Dist.] 1991, no pet.) (appeal of denial of pretrial habeas application rendered moot
by appellant’s subsequent conviction for underlying robbery).
Here, the premise of Boyd’s habeas application—his request for reduced
pretrial bail—has been “destroyed by subsequent developments.” See Bennet, 818
S.W.2d at 200. Because Boyd has now been tried and convicted in the underlying
murder cases, the issue of pretrial bail with respect to those offenses is moot. See Ex
parte Tucker, 3 S.W.3d 576, 576 (Tex. Crim. App. 1999) (“The appellant having
been tried during the pendency of this appeal, the question of his pre-trial bond is
moot.”); Martinez v. State, 826 S.W.2d 620, 620 (Tex. Crim. App. 1992) (dismissing
as moot challenge to ruling on pretrial bail issue where applicant was convicted in
underlying case and no longer subject to pretrial confinement); Ex Parte Green, No.
4
01-26-00204-CR, 2026 WL 994644, at *1 (Tex. App.—Houston [1st Dist.] Apr. 14,
2026, no pet. h.) (mem. op., not designated for publication) (“[B]ecause appellant
has been convicted of the underlying offense and is no longer subject to pretrial
confinement, his appeal is moot.”).
Although Boyd’s aggravated-assault offense remains outstanding, there is no
action that this Court can now take with respect to pretrial bail that will be of any
practical effect—as Boyd is now serving a sentence of 22 years in the related cases.
See Bennet, 818 S.W.2d at 200 (“[B]ecause appellant is now legally confined
pursuant to a guilty verdict in the underlying robbery case . . . [t]here is no action
this court can now make regarding the trial court’s decision on the amount of bail
that will cause any effect.”).6
6
See, e.g., Ex parte Bell, No. 01-22-00473-CR, 2022 WL 17419582, at *5 (Tex.
App.—Houston [1st Dist.] Dec. 6, 2022, no pet.) (mem. op., not designated for
publication); Ex parte Joyner, 367 S.W.3d 737, 738 (Tex. App.—Houston [14th
Dist.] 2012, no pet.).
5
Conclusion
We dismiss Boyd’s appeal in each cause number as moot. We dismiss any
other pending motions as moot.
Terry Adams
Chief Justice
Panel consists of Chief Justice Adams and Justices Gunn and Johnson.
Do not publish. TEX. R. APP. P. 47.2(b).
6