James Hoyt Mcbrayer v. State Texas

The record reflects that appellant, before the trial of the case, made a motion for change of venue alleging a dangerous combination against him was instigated by influential persons since the complainants mother "is...well respected and generally held in high regard by the courthouse community, including judges, lawyers, district attorneys, and law enforcers, and that because of this high regard, the defendant has been unable to hire attorneys of his own choice." The motion was supported by the affidavits of appellants mother and two attorneys who all attested that because of appellants difficulty in retaining counsel of his own choice a great prejudice existed against him in Tarrant County. No controverting affidavit was filed by the State.