Burnam v. State — Appeals abated for corrected right-to-appeal certifications

Case
William Wayne Burnam v. The State of Texas
Court
Texas Seventh Court of Appeals
Judge
Doss; Yarbrough; Pratt
Date Decided
August 19, 2026
Docket No.
07-26-00332-CR; 07-26-00333-CR; 07-26-00334-CR
Topics
Criminal Appeals; Right to Appeal; Abatement; Trial Court Certification
Source
Read the full opinion

Background

William Wayne Burnam appealed judgments adjudicating him guilty of violating a protective order, stalking, aggravated assault, and possession of a controlled substance. The appeals arose from multiple trial-court causes in Randall County’s 47th District Court.

The trial court signed certifications of Burnam’s right of appeal in each cause on July 10, 2026. The certifications were incomplete, however, because they did not indicate whether Burnam had a right to appeal.

The Court’s Holding

The Texas Seventh Court of Appeals held that the incomplete certifications were defective. It abated the appeals and remanded the causes so the trial court could prepare amended certifications stating whether Burnam has a right to appeal.

The court directed the trial court to use reasonable means to obtain Burnam’s signature on the amended certifications. It also ordered that the amended certifications be included in supplemental clerk’s records filed with the appellate court by September 18, 2026.

Key Takeaways

  • A trial court’s certification must indicate whether a criminal defendant has a right to appeal.
  • Defective certifications may require abatement and remand for correction before the appeals proceed.
  • The trial court must use reasonable means to secure the defendant’s signature on the amended certifications.

Why It Matters

The order underscores that a complete and record-supported certification of the defendant’s appellate rights is a necessary procedural step in a Texas criminal appeal. Here, the appellate court did not decide the merits; it paused the appeals so the trial court could correct the certification defect.

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