TDCAA is doing an update of the Predicate Manual. Are there any new predicates you would like to see?

John Bradley
District Attorney
Williamson County, Texas

Since TDCAA is concerned about the County Attorneys supporting the CPS trial workload, how about some predicates for typical CPS stuff, like relinquishment of parental rights; status hearing; removal hearing; etc.


Thanks for asking.

The Predicates Manual is designed to give the prosecutor a handy tool for asking the basic questions necessary to establish the predicate required for admission of a particular item of evidence or opinion of a witness. It isn't a how-to manual for specialized areas, such as CPS litigation.

Of course, the predicates for evidence such hearings, is pretty much the same as in a criminal case, if not easier.

So, I was actually looking for suggestions on types of evidence not currently covered by the Predicates Manual.

For example, I will be adding the predicate questions used to get the results of a dog sniff identification of a defendant into evidence. That should be handy, eh?

John Bradley
District Attorney
Williamson County, Texas

It will be handy since we use the services of Fort Bend County's scent discriminating bloodhounds named Quincy and Columbo.

One other thing, Mike: Two wonderful prosecutors in Tarrant County are going to be working on a CPS/terminations book shortly. Anne Swenson and David Curl, who speak on CPS-related issues for the State Bar and who work primarily in Tarrant County's Appellate Division, will be putting together a proposal for the next publications committee meeting. TDCAA, meanwhile, will look at various ways to get the manual in the hands of all prosecutors who could use it.

car data recorders

John, Diane, thanks.

But, I can't see that CPS work is a "specialized area" if every County Attorney is expected to represent CPS.

I may be mistaken, but I think DFPS puts out some materials, including trial predicates and canned questions, for CPS cases that they will provide to you as their courtroom advocate. If you'll e-mail me, I'll put you in direct touch with our CPS lawyer, who may be able to provide you with more informed guidance.

Sometimes information is an admixture or hybrid; e.g., a human being inputs information from time to time but after such entry, an electronic or mechanical process takes over. Cell phone records cometo mind. I'm sure sharper minds will think of better examples....

predicate for DRE's would be pretty useful. Had a trial where I just sort of "winged" it and have used the same procedure two other times. I know the DRE situation doesn't come up alot, but then again, that's kinda the purpose!!!!

Thanks!!!!

This may be more approp. for another forum, but my tech. supervisor has questions that she likes better than the predicate questions and still covers most of the predicate. Is this common among tech. supervisors?

The latest update for the Predicate Manual is done. Look for your copy soon, compliments of the granting authorities for TDCAA.

Nice plug.

More of a public service announcement.

At last! Man, I've been waiting for that one. So much more entertaining than that lunatic fringe sleep aid they call Future Danger by that what's-his-name. (Public service announcement in reverse)

Nothing like the respect of a fellow author to keep me going.

Does this version have pictures?

An excellent suggestion for the next edition. Perhaps some candid shots of the author at work.