In Texas capital cases, a person convicted under the law of parties may not be sentenced to death if convicted under the law of parties unless the sentencing jury finds beyond a reasonable doubt that "the defendant actually caused the death of the deceased or did not actually cause the death of the deceased but intended to kill the deceased or another or anticipated that a human life would be taken.
[3][4] People sentenced to death under the law include Carlos Santana,[5] Carlos Trevino,[6] Cleve Foster,[7] Clinton Young,[8] Donald Newbury,[9] Doyle Skillern,[10] George Rivas,[11] G.W.
Green,[12] Humberto Garza,[13] Jeffery Wood, Jessie Gutierrez,[14] John Adams,[15] Joseph Garcia,[16] Joseph Nichols,[17][18] Juan Ramirez,[19] Kenneth Foster, Michael Rodriguez,[20] Miguel Martinez,[21] Patrick Murphy, Randy Halprin, Ray Jasper,[22] Robert Garza,[23] Robert Pruett, Robert Thompson,[24] Rodolfo Medrano,[25] Steven Woods, and Ignacio Cuevas.
[26] Kenneth Foster and Miguel Martinez's sentences would later be commuted to life imprisonment.
Clinton Young was released on bond in 2022 after his conviction was overturned due to prosecutorial misconduct.