Saturday, February 14, 2026

Charles Flores: Texas: "Football, Death Row, and hypnotized witness testimony:" His capital case puts hypnotic refreshment (creation of false memories) under the microscope, the Death Penalty Information Center (Author Hayley Bedard) reports, noting that: "In 2016, Mr. Flores came with­in five days of exe­cu­tion before his date was stayed by the Texas Court of Criminal Appeals (TCCA) to allow him to lit­i­gate a claim that pros­e­cu­tors uncon­sti­tu­tion­al­ly obtained his con­vic­tion through the use of unre­li­able hyp­not­i­cal­ly refreshed tes­ti­mo­ny. According to an affi­davit Mr. Flores sub­mit­ted to the court from psy­chol­o­gy pro­fes­sor Steven Lynn, research has linked “hyp­not­ic refresh­ment” with the cre­ation of false mem­o­ries. “Clearly, the tech­niques that were used to refresh [the witness’s] mem­o­ry would be eschewed today by any­one at all famil­iar with extant research on hyp­no­sis and mem­o­ry,” Prof. Lynn wrote."


PASSAGE OF THE DAY: "2020 Dallas Morning News inves­ti­ga­tion exam­ined the use of inves­tiga­tive hyp­no­sis in Texas, and report­ed that since the 1980s, the Texas Department of Public Safety used inves­tiga­tive hyp­no­sis in crim­i­nal inves­ti­ga­tions at least 1,700 times, lead­ing to prison sen­tences for dozens of peo­ple and death sen­tences for oth­ers. Experts iden­ti­fied for The News four con­cerns with the use of hyp­no­sis by Texas law enforce­ment in crim­i­nal inves­ti­ga­tions: sug­gestibil­i­ty affects sub­jects, crit­i­cal-think­ing abil­i­ties may dimin­ish,  “con­fab­u­la­tion” occurs when sub­jects fill mem­o­ry gaps with fic­tion­al events, and fab­ri­cat­ed mem­o­ries can solid­i­fy through  “mem­o­ry cemen­ta­tion” over time."

PASSAGE TWO OF THE DAY:  "On the heels of this report­ing, Texas Rangers (law enforce­ment) ceased using hyp­no­sis in inves­ti­ga­tions and law­mak­ers passed leg­is­la­tion in 2023 that ulti­mate­ly bans the use of hyp­no­sis-based tes­ti­mo­ny in crim­i­nal pro­ceed­ings. Mr. Flores did not obtain relief under this new law, as it does not apply retroac­tive­ly, despite state lead­ers’ acknowl­edge­ment of the unre­li­a­bil­i­ty of the tech­nique as evidence."

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    STORY: "Football, Death Row, and Hypnotized Witness Testimony: The Case of Charles Flores by  Communications Associate Hayley Bedard, published by The Death Penalty Information Center, on February 9, 2026.

    Among the more than 100 mil­lion Americans watch­ing the Super Bowl on Sunday, Charles Flores (pic­tured) watched from a 9‑by-12-foot cell in Livingston, Texas, mark­ing his 27th Super Bowl on death row for a crime he has main­tained he did not com­mit.

     In a pod­cast inter­view with Pablo Torre, a jour­nal­ist and sports­writer, Mr. Flores sat down at the Polunsky Unit in Livingston to dis­cuss his love of the Dallas Cowboys, watch­ing the Super Bowl on death row, the intri­ca­cies of his fight to prove his inno­cence, and how his con­vic­tion hinges on the use of a hyp­no­tized wit­ness.

    In con­ver­sa­tion with Mr. Torre, Mr. Flores described what it means to fol­low foot­ball from soli­tary con­fine­ment, where he spends 23 hours a day in a cell. 

    On game days, he stacks legal doc­u­ments from his decades-long case to cre­ate a makeshift stool, posi­tion­ing him­self close enough to see through the wire cutouts to a com­mu­nal tele­vi­sion mount­ed 30 feet down the hall.  “When it’s third and 10 or what­ev­er, I get up,” Mr. Flores said.  “I have to get as close as I can get.”

     Mr. Flores received access to his first tele­vi­sion in 2023, after 24 years with­out one. The first game he watched was the Super Bowl between Kansas City and Philadelphia.

     He described this expe­ri­ence as  “amaz­ing” and spoke to Mr. Torre about how foot­ball serves a spe­cif­ic pur­pose beyond enter­tain­ment for pris­on­ers on death row:  “When you’re sent to prison, you’re tak­en away from your peo­ple, your clan, from every­thing you know and love,” he said.  “Being a fan — me being a Cowboy fan or the broth­ers back there being super hype about the Houston Texans — that’s their con­nec­tion to the free world. It’s not just them. It’s mom at home. It’s dad at home.”

    Mr. Flores was con­vict­ed and sen­tenced to death in 1999 for the 1998 rob­bery and mur­der of Elizabeth  “Betty” Black in her Texas home.

     He was con­vict­ed based on the tes­ti­mo­ny of Jill Barganier, one of Ms. Black’s neigh­bors, who only iden­ti­fied Mr. Flores after being hyp­no­tized by police — 13 months after the crime occurred. No DNA or phys­i­cal evi­dence ties Mr. Flores to the crime. 

    The jury did not know that imme­di­ate­ly fol­low­ing the crime, Ms. Barganier described two indi­vid­u­als who came out of Ms. Black’s home who did not look like Mr. Flores, and she failed to iden­ti­fy him in a pho­to line-up at that time. 

    The first time she iden­ti­fied Mr. Flores was dur­ing tri­al, after she had gone through the inves­tiga­tive hyp­no­sis and had been exposed to Mr. Flores’ pho­to on multiple occasions.

    At the time of the crime, Ms. Barganier told the police she rec­og­nized one of the two men she saw as Richard Childs, whom she knew.

     She was unable to iden­ti­fy the sec­ond indi­vid­ual, even after being shown images of Mr. Flores.

     Under hyp­no­sis by a police-employed hyp­no­tist, she repeat­ed her iden­ti­fi­ca­tion of the sec­ond man, char­ac­ter­iz­ing both indi­vid­u­als as white men with sim­i­lar builds and long hair. 

    Mr. Flores did not match her descrip­tion — he is Hispanic and wore his hair shaved short — con­tra­dict­ing each of the iden­ti­fy­ing fac­tors brought to law enforcement’s atten­tion.

     Following the hyp­no­sis ses­sion, Ms. Barganier again failed to iden­ti­fy Mr. Flores in a pho­to-line­up of only Hispanic males, none of whom matched the descrip­tion she pro­vid­ed of the second individual.

    Mr. Childs con­fessed to shoot­ing Ms. Black, pled guilty and was sen­tenced to a term of 35 years with parole eli­gi­bil­i­ty after 17 years. 

    He was released on parole in April 2016. 

    Mr. Flores at the time admit­ted to his involve­ment in the drug trade but main­tained he was not involved in Ms. Black’s death. 

    Under Texas’ law of par­ties, a per­son can be charged with cap­i­tal mur­der and sen­tenced to death if they par­tic­i­pat­ed in a felony that result­ed in a mur­der, even if they did not kill any­one them­selves. 

    The law holds accom­plices equal­ly respon­si­ble as the per­son who com­mit­ted the killing. Mr. Flores was con­vict­ed under this statute as a know­ing par­tic­i­pant in the rob­bery and murder. 

    In 2016, Mr. Flores came with­in five days of exe­cu­tion before his date was stayed by the Texas Court of Criminal Appeals (TCCA) to allow him to lit­i­gate a claim that pros­e­cu­tors uncon­sti­tu­tion­al­ly obtained his con­vic­tion through the use of unre­li­able hyp­not­i­cal­ly refreshed tes­ti­mo­ny. 

    According to an affi­davit Mr. Flores sub­mit­ted to the court from psy­chol­o­gy pro­fes­sor Steven Lynn, research has linked  “hyp­not­ic refresh­ment” with the cre­ation of false mem­o­ries.  “Clearly, the tech­niques that were used to refresh [the witness’s] mem­o­ry would be eschewed today by any­one at all famil­iar with extant research on hyp­no­sis and mem­o­ry,” Prof. Lynn wrote.

     Mr. Flores learned about his stay of exe­cu­tion while lis­ten­ing to the same radio that he had lis­tened to foot­ball games on and told Mr. Torre that  “it was sur­re­al.” Despite the evi­dence dis­cred­it­ing hyp­not­ic refresh­ment, the state court reject­ed Mr. Flores’ appeal in 2017, and in 2020, the TCCA upheld the ruling.

    A 2020 Dallas Morning News inves­ti­ga­tion exam­ined the use of inves­tiga­tive hyp­no­sis in Texas, and report­ed that since the 1980s, the Texas Department of Public Safety used inves­tiga­tive hyp­no­sis in crim­i­nal inves­ti­ga­tions at least 1,700 times, lead­ing to prison sen­tences for dozens of peo­ple and death sen­tences for oth­ers.

     Experts iden­ti­fied for The News four con­cerns with the use of hyp­no­sis by Texas law enforce­ment in crim­i­nal inves­ti­ga­tions: sug­gestibil­i­ty affects sub­jects, crit­i­cal-think­ing abil­i­ties may dimin­ish,  “con­fab­u­la­tion” occurs when sub­jects fill mem­o­ry gaps with fic­tion­al events, and fab­ri­cat­ed mem­o­ries can solid­i­fy through  “mem­o­ry cemen­ta­tion” over time.

     On the heels of this report­ing, Texas Rangers (law enforce­ment) ceased using hyp­no­sis in inves­ti­ga­tions and law­mak­ers passed leg­is­la­tion in 2023 that ulti­mate­ly bans the use of hyp­no­sis-based tes­ti­mo­ny in crim­i­nal pro­ceed­ings. 

    Mr. Flores did not obtain relief under this new law, as it does not apply retroactively, despite state leaders acknowledgment of the unreliability of the technique as evidence.


     In June 2025, coun­sel for Mr. Flores filed a motion argu­ing he should be grant­ed a new tri­al because of changes in the under­stand­ing of wit­ness tes­ti­mo­ny and changes in law regard­ing the use of hyp­no­tized wit­ness­es since 1999.

     Among the fil­ings were new expert dec­la­ra­tions that cast even fur­ther doubt on the integri­ty of Mr. Flores’ con­vic­tion. In October 2025, the peti­tion was dis­missed because the court con­sid­ered it pro­ce­du­ral­ly barred. The mer­its of Mr. Flores’ claims have still not been addressed. 

    Mr. Flores has exhaust­ed all his appeals. He told Mr. Torre,  “I just want a fair review. I just want a fair shot.” Mr. Flores not­ed that the Dallas District Attorney’s Office has a Conviction Integrity Unit and­ hopes that the unit will con­sid­er review­ing his case and actu­al innocence claim. 


    , despite state lead­ers’ acknowl­edge­ment of the unre­li­a­bil­i­ty of the tech­nique as evidence. 

    In June 2025, coun­sel for Mr. Flores filed a motion argu­ing he should be grant­ed a new tri­al because of changes in the under­stand­ing of wit­ness tes­ti­mo­ny and changes in law regard­ing the use of hyp­no­tized wit­ness­es since 1999. 

    Among the fil­ings were new expert dec­la­ra­tions that cast even fur­ther doubt on the integri­ty of Mr. Flores’ con­vic­tion. In October 2025, the peti­tion was dis­missed because the court con­sid­ered it pro­ce­du­ral­ly barred. The mer­its of Mr. Flores’ claims have still not been addressed. 

    Mr. Flores has exhaust­ed all his appeals. He told Mr. Torre,  “I just want a fair review. I just want a fair shot.” Mr. Flores not­ed that the Dallas District Attorney’s Office has a Conviction Integrity Unit and­hopes that the unit will con­sid­er review­ing his case and actu­al innocence claim."


    The entire story can be read at:


    https://deathpenaltyinfo.org/football-death-row-and-hypnotized-witness-testimony-the-case-of-charles-flores


    PUBLISHER'S NOTE:  I am monitoring this case/issue/resource. Keep your eye on the Charles Smith Blog for reports on developments. The Toronto Star, my previous employer for more than twenty incredible years, has put considerable effort into exposing the harm caused by Dr. Charles Smith and his protectors - and into pushing for reform of Ontario's forensic pediatric pathology system. The Star has a "topic"  section which focuses on recent stories related to Dr. Charles Smith. It can be found at: http://www.thestar.com/topic/charlessmith. Information on "The Charles Smith Blog Award"- and its nomination process - can be found at: http://smithforensic.blogspot.com/2011/05/charles-smith-blog-award-nominations.html Please send any comments or information on other cases and issues of interest to the readers of this blog to: hlevy15@gmail.com.  Harold Levy: Publisher: The Charles Smith Blog.

    SEE BREAKDOWN OF  SOME OF THE ON-GOING INTERNATIONAL CASES (OUTSIDE OF THE CONTINENTAL USA) THAT I AMFINAL WORD:  (Applicable to all of our wrongful conviction cases):  "Whenever there is a wrongful conviction, it exposes errors in our criminal legal system, and we hope that this case — and lessons from it — can prevent future injustices."

    Lawyer Radha Natarajan:

    Executive Director: New England Innocence Project;


    FINAL WORD:  (Applicable to all of our wrongful conviction cases):  "Whenever there is a wrongful conviction, it exposes errors in our criminal legal system, and we hope that this case — and lessons from it — can prevent future injustices."

    Lawyer Radha Natarajan:

    Executive Director: New England Innocence Project;

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    FINAL, FINAL WORD: "Since its inception, the Innocence Project has pushed the criminal legal system to confront and correct the laws and policies that cause and contribute to wrongful convictions.   They never shied away from the hard cases — the ones involving eyewitness identifications, confessions, and bite marks. Instead, in the course of presenting scientific evidence of innocence, they've exposed the unreliability of evidence that was, for centuries, deemed untouchable." So true!


    Christina Swarns: Executive Director: The Innocence Project;

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