Educational Purpose

 Manus is just Claude Sonnet with some other tools. Claude can do the same (and better) with the proper skills: https://github.com/obra/superpowers

Here is an example of some counter arguments and responses the agent gave me:

ANTICIPATED COUNTERARGUMENT #1:
"Chapter 45A authorizes complaints, which serve the same function as informations
in municipal court."

RESPONSE:

This argument fails for three reasons:

First, LEGAL DISTINCTION: A complaint is not an information. These are legally
distinct instruments:
  - Information (Art. 27.03): Filed by prosecuting attorney under oath
  - Complaint (Art. 45.019): Filed by "any credible person"
Different issuing authority = different legal status.

Second, STATUTORY HIERARCHY: Article 27.01 says the primary pleading "IS the
indictment or information" - not "complaint." If Legislature intended complaints
to substitute for informations in municipal courts, it would have amended Article
27.01 to state: "except in justice or municipal courts, where complaints may
serve as primary pleadings." It did not.

Third, ARTICLE 27.14(b) DISTINCTION: That provision mentions "indictment,
information, or complaint" as separate instruments. The Legislature knows how
to list multiple acceptable pleadings when intended. Article 27.01 lists only
two: indictment or information.

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ANTICIPATED COUNTERARGUMENT #2:
"Long-standing practice shows municipal courts accept citations/complaints without
informations."

RESPONSE:

Long-standing error does not become law. Courts must follow statutory text, not
custom or tradition.

If municipal courts have been proceeding without primary pleadings for decades,
that demonstrates systemic non-compliance with Article 27.01, not that Article
27.01 doesn't apply.

The absence of prior challenges proves only that most defendants lack knowledge
or resources to raise this issue, not that the practice is legally correct.

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ANTICIPATED COUNTERARGUMENT #3:
"This would invalidate all municipal court prosecutions - absurd result."

RESPONSE:

First, the remedy for statutory non-compliance is COMPLIANCE, not ignoring the
statute. The State can file informations in municipal courts. Article 27.03 does
not prohibit this.

Second, if the Legislature wishes to exempt municipal courts from the primary
pleading requirement, it can amend Article 27.01 to explicitly state the exception.
The judiciary cannot rewrite statutes based on convenience.

Third, the "absurd results" canon does not apply where the statutory text is
clear and unambiguous. Article 27.01 plainly states what the primary pleading IS.

Filed our petition for review this afternoon in the California Supreme Court. The issue under CCP § 1161(a)(b)1 is ambiguous and has far reaching implications which impact public interest. Can a summary unlawful detainer proceeding for possession of real property (after a contested sale and contested title to pay a judgment where the court has no threshold jurisdiction to begin with), proceed based on presumptions that the statute was met and fulfilled by the lower court? The statute dictates that the title must be "duly perfected" to obtain jurisdiction, and it was not. The presumption is that the court must have met the statutory requirements, notwithstanding, no evidence was ever shown to document that the statutory requirements were met in accordance with legislative intent. The burden of proof was shifted from the plaintiff to the defendant. Hopefully the court of supremeness will review the matter and order the case remanded for failure to follow the strict interpretation and language of the law.

I utilize the projects tab. You can keep your research and everything in one “project”, and you can customize it to where AI will only refer to the work being done within the project, and it won’t start mentioning things you have discussed outside of the project. I found that helpful to keep the AI on topic

.Texas Attorney General Opinion DM-291

Rushing v. State, 546 S.W.2d 610 (Tex. Grim. App. 1977) (holding that it was not error for indictment to aver that the offense occurred in Dallas County when offense actually occurred in another county within four hundred yards of the Dallas County line).

For example, because section 13.22 of the Code of Criminal Procedure provides for the prosecution of the offense of possession or delivery of marihuana, with the consent of the defendant, in a county that is adjacent to and in the same judicial district as the county where the offense was committed, a grand jury in such a county may properly return an indictment for such an offense. See gener&

A Kleberg County grand jury may return an indictment for an offense committed in Kenedy County for which venue in Kleberg County is proper. The determination whether it is appropriate for a grand jury to return an indictment for a particular offense Committed in another county must be made on a case by case basis.

https://www.texasattorneygeneral.gov/sites/default/files/opinion-files/opinion/1994/dm0291.pdf

Interesting...in 2016 the Victoria County Criminal District Attorney asked the following in RQ0129KP.pdf ( https://www.texasattorneygeneral.gov/sites/default/files/request-files/request/2016/RQ0129KP.pdf ):

Specifically, I ask the Attorney General the following: when a grand jury conducts an Article 2.03 investigation does the grand jury; (1) generate a report memorializing findings of "any act of violation of law or neglect or failure of duty upon the part of any officer"; (2) if such a report is made how should the grand jury report its findings to its convening authority; (3) if the grand jury presents such a report to the district clerk must such a clerk of the court present it to the convening authority; (4) would such a report if in the possession of the district clerk become a public record subject to disclosure. 

The summary answer was provided in kp0137 ( https://www.texasattorneygeneral.gov/sites/default/files/opinion-files/opinion/2017/kp0137.pdf ):

The Legislature authorized grand juries to inquire into all offenses liable to indictment and report their findings by the return or rejection of an indictment.

As article 2.03(a) of the Code of Criminal Procedure does not implicitly grant the grand jury additional authority to issue reports other than indictments, a district clerk has no legal obligation to accept a grand jury report prepared under article 2.03(a) as part of an investigation into official misconduct.

Note for later:
There are multi-county districts.  A grand jury could conceivably deliver an indictment in one county where the venue works be in a different county.  This needs to be researched further.

Randy K  I asked Grok "Please ask identify Texas criminal court cases where the county of venue was different than the county where the grand jury was impaneled which delivered the indictment.  Do not include cases where there was a change of venue."

Grok replied with:

A relevant Texas Attorney General Opinion (DM-0291, 1994) addresses multi-county judicial districts (e.g., the 105th Judicial District covering Kleberg, Kenedy, and Nueces Counties). It concludes that a grand jury in one county can indict for an offense in another county within the district only if venue is proper in the indicting county (based on venue statutes or consent). If venue is not proper, the indictment is typically dismissed, and the case is re-indicted in the correct county. This does not result in a trial under the original indictment in a different county without a change of venue.

https://www.texasattorneygeneral.gov/opinions/dan-morales/dm-0291

https://www.texasattorneygeneral.gov/sites/default/files/opinion-files/opinion/1994/dm0291.pdf

Also from DM-0291:

We also note that the legislature has provided that when an offense may be prosecuted in either of two or more counties, “the indictment may allege the offense to have been wmmitted in the county where the same is prosecuted or in any county or place where the offense was actually committed.” Code Crim. Proc. art. 21.06; see also Rushing v.
SrOre, 546 S.W.2d 610 (Tex. Grim. App. 1977) (holding that it was not error for indictment to aver that the offense occurred in Dallas County when offense actually occmred in another county within four hundred yards of the Dallas County line).

District Judge Mary Lou Alvarez ruled that no attorneys with Paxton’s office could try the case, and that the suit would be dismissed in a week unless authorized counsel took their place. The county’s immigration services program’s end is scheduled for Feb. 28, a day after the court’s deadline to Paxton’s office.

https://www.sacurrent.com/news/san-antonio-news/judge-blocks-texas-ags-bid-to-shut-bexar-county-immigrant-legal-aid-program/

yes, when reading between the lines it seems like this is present to give the ability (and even warning) to object to the citation, or even sworn complaint, being used as the primary pleadings before the trial, but if not raised you tacitly agree to it being acceptable. I've seen in some appelate opinions this is referenced to say the objection to the charging instrument is invalid because it was not made before trial.

Right... You better raise it before the trial on the merits.  What Randy said about dirruzo v state still applies too...which is that it's not proper to interpret one law in such a way that it renders another superfluous.