austindefender

Criminal defense in Austin Texas.

Writ of Habeas Corpus Improper Photography, pages 1-2

Posted By on July 13, 2009

Cause Number _____________

In The

District Court of Williamson County

277th Judicial District

Williamson County, Texas

In re

xxx

Petition for Writ of Habeas Corpus

and

Brief in Support Thereof

Lance Stott

Attorney for Applicant

SB# 00797818

812 San Antonio, Suite 403

Austin, Texas 78701

(512) 472-0557 telephone

(512) 472-9908 facsimile

Petition for Writ of Habeas Corpus

Lance Stott, Petitioner and attorney for xxx, makes this Petition for Writ of Habeas Corpus on behalf of Applicant, and in support thereof would show the Court that the Texas law “Improper Photography” is unconstitutional, because it violates the First Amendment of the United States Constitution, and the Constitution of the State of Texas, Article I, §8. Because an unconstitutional law is as no law, and is void, it may not be made the basis for the prosecution of any person, nor may any person be held to bond, or otherwise be deprived of liberty, on the basis of such a law.

Applicant is illegally restrained in his liberty by the Sheriff of Williamson County, in that he is held to bond in cause number xxx The State of Texas v. xxx, in Williamson County, Texas.

For these reasons, and for the reasons set forth in the Petitioner’s Brief in Support of this Petition, Petitioner prays for relief. Specifically, Petitioner prays for an Order from this Court requiring the State of Texas to dismiss its prosecution of Applicant, and for the reason that Texas Penal Code §21.15(b)(1) is unconstitutional.

Respectfully Submitted,

________________________

Lance Stott

Attorney for Applicant

SB# 00797818

812 San Antonio, Suite 403

Austin, TX 78701

(512) 472-0557 telephone

(512) 472-9907 facsimile


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