U.S. Supreme Court unanimously keeps 60-year prison sentence for San Antonio murder defendant intact

Ruling resolves Sixth Amendment dispute over attorney-client consultation during an overnight recess in testimony

The U.S. Supreme Court on Wednesday, February 25, 2026, unanimously upheld the 60-year prison sentence of David Asa Villarreal, a San Antonio man convicted of murder in the 2015 stabbing death of his boyfriend, Aaron Estrada. The decision leaves in place the judgment of the Texas Court of Criminal Appeals and ends Villarreal’s bid for a new trial based on how the trial judge managed attorney-client communication during an overnight break while Villarreal was testifying.

Estrada, 29, was killed on October 16, 2015, inside his apartment in the 12000 block of West Avenue. Villarreal was convicted by a Bexar County jury and sentenced on June 25, 2018, to 60 years in prison. At trial, the defense argued Villarreal acted in self-defense during a confrontation described as drug-fueled, contending Estrada choked Villarreal before the stabbing.

The legal issue: a “qualified” ban on discussing ongoing testimony

The appeal centered on an order issued by the presiding trial judge during a 24-hour overnight recess that interrupted Villarreal’s testimony. The judge told defense counsel they could speak with their client during the recess but instructed them not to “manage” Villarreal’s testimony—effectively barring discussion of his ongoing testimony while allowing consultation on other matters, including potential sentencing issues.

Villarreal argued that restricting attorney-client discussion during an overnight recess violated the Sixth Amendment right to counsel. Texas argued the order was narrowly drawn to prevent coaching during testimony while preserving constitutionally protected consultation on other trial-related topics.

How the Supreme Court drew the constitutional line

In an opinion authored by Justice Ketanji Brown Jackson, the Court concluded the order did not “ban or impermissibly chill” constitutionally protected consultation. The Court framed the key distinction as substantive rather than purely based on the length of the break: while a defendant has a right to consult counsel on broader matters, the Constitution does not protect consultation specifically aimed at shaping ongoing testimony while the defendant remains under oath.

The Court’s reasoning relied on the boundary it has previously drawn between two earlier precedents: one that prohibits complete bans on attorney-client communication over an overnight recess, and another that allows limits during a brief recess to prevent coaching. The justices concluded the order at issue fit within constitutional limits because it targeted only testimony-specific “management” while preserving consultation on other protected subjects.

• The ruling was unanimous: all nine justices voted to affirm the Texas court’s judgment.

• Separate concurring opinions were filed by Justices Samuel Alito, Clarence Thomas, and Neil Gorsuch.

The decision means Villarreal’s 60-year sentence remains in effect and the conviction stands without further review from the nation’s highest court.

The ruling is expected to guide how trial courts structure narrowly tailored “conferral” restrictions when a defendant’s testimony spans recesses, particularly when courts seek to balance anti-coaching concerns with the Sixth Amendment right to counsel.