St. Julian v. State
Texas Court of Criminal Appeals
874 S.W.2d 669 (1994)
- Written by Kelli Lanski, JD
Facts
Ronald St. Julian (defendant) was convicted of burglary of a building with intent to commit theft. The building was an apartment-complex mailroom. The mailroom was made of brick and had a roof and four walls. It did not have a door; instead, it was accessible via an open archway. Any member of the public could access the mailroom through the open archway from a public street. The mailroom was part of a larger two-story brick structure containing apartment units and a clubhouse area, all of which were connected by open passages to public streets. St. Julian appealed his conviction, arguing that the mailroom was an unenclosed structure and therefore did not fall under Texas’s burglary statute, which required entry into a building. The first appellate court agreed with the state that the mailroom was part of the apartment building and therefore protected under the burglary statute. St. Julian appealed to the Texas Court of Criminal Appeals.
Rule of Law
Issue
Holding and Reasoning (Maloney. J.)
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