OPINION

delivered the opinion of the Court in which

A jury convicted appellant of aggravated sexual assault of a child. During the punishment phase, appellant .testified and admitted that he had had an ongoing sexual relationship with the young girl. The court of appeals held that, under the judicially created DeGarmo 1 doctrine, as modified by Leday,2 appellant was es-topped from complaining about the State’s jury argument during the guilt phase because he had later admitted his guilt. Therefore, the court was precluded from addressing the. merits of appellant’s claim.3 We granted appellant’s petition for discretionary review to decide whether Leday’s exceptions to the DeGarmo estoppel doctrine should “be extended to a broader class of guilty-phase errors.”4 We conclude that Leday’s reasoning applies to all guilt-stage claims of error, not merely “fundamental” claims, and we overrule any last vestiges of the DeGarmo doctrine.5 Therefore, a defendant who testifies at the punishment stage of trial and admits his *197guilt does not forfeit his right to complain on appeal about errors occurring during the guilt stage. We remand this case to the court of appeals to address the merits of appellant’s complaint.

I.

Appellant’s mother was a friend of B.P.’s family. Appellant and B.P. had known each other all of their lives. When he was twenty and B.P. was twelve, appellant moved in with her family. At first, appellant treated B.P. like a little sister, but then he started touching her inappropriately and, eventually, started having sex with her. This relationship lasted for about eight months — until B.P.’s mother began to notice a decline in B.P.’s grades and a general change in her attitude. Something was wrong. B.P.’s family kicked appellant out of their house because they were suspicious of his influence over B.P.

Someone reported B.P.’s mother to CPS for not taking appropriate care of her daughter. CPS determined that this charge was unfounded, but the investigators found “love letters” between appellant and B.P. and called the police. B.P. then admitted that she and appellant had had sex on many occasions.

B.P. testified that appellant told her that he “wanted to expand [her] horizons” as he got more sexual and more possessive. B.P. said that appellant was a “Goth”— “[wjearing all black, listening to heavy metal, you know, tattoos, black hair, all that stuff.” At first he would put his fingers in her vagina and she would “blow” him, but then appellant “wanted to take it a step farther.” Soon, they ended up having sex “just about every day.” Appellant told B.P. that he loved her and wanted to marry her.

Detective Richard Mayer of the Lubbock Sheriffs Office, testified that B.P. was initially reluctant to discuss her sexual relationship with appellant, but she eventually admitted to the relationship. On cross-examination, Det. Mayer said that, at the beginning of his investigation, he did not know if appellant was innocent or guilty. Once B.P. admitted that appellant had had sex with her, he explained that

I still knew that even with her saying yes that I would need more to prove the case, which would be the CARE exam. So I wasn’t like, ‘Oh, I got this one in my win pile,’ you know.... I still have to go through the steps of investigation to be sure that I’m not just falsely accusing somebody of something.

During closing arguments, defense counsel seized on Det. Mayer’s “win pile” phrase and repeatedly suggested that his investigation had “turned into a global warming Salem witch hunt trial.” He said that Det. Mayer had “jumped to conclusions.” Then counsel came back to his “witch hunt” theme:

And the thing about it is the witch hunt. You know when witch hunts were happening, they thought there was a witch. They tied them up. Weighted them down. Threw them in the water. If they survived, they were a witch. If they didn’t survive, well, better safe than sorry.

Ladies and gentlemen, we got rid of those witch hunts.... Ladies and gentlemen, our system must never be law enforcement saying, “I got to get enough to put it in the win pile.”

He claimed that Det. Mayer “started out with ‘How do I get this to the win pile? How do I get the witch in the water?”’

The prosecutor immediately responded to counsel’s characterization of Det. Mayer’s testimony by noting, “Somebody in this courtroom has an end result that they will twist and turn and fill in the holes to *198make it work ... whatever they want to do to make it happen.” Defense counsel objected that the prosecutor was “attacking Defendant over counsel’s shoulder,” but the trial judge overruled him, and the prosecutor continued:

The Defense in this case has their end result, and they will twist the words of Detective Mayer. And if you don’t believe me, how many times did he stand up here and use the words “win pile”?

The jury found appellant guilty of aggravated sexual assault. Then, during the punishment phase, appellant testified and admitted to having a “sexual relationship” with twelve-year-old B.P., but stated that “she was the one kind of teaching [him] some of these things.” The jury sentenced appellant to forty-five years in prison.

Appellant’s sole claim on appeal was that the trial judge erred in overruling his objection to the prosecutor’s argument. The court of appeals noted that, before it could reach the merits of this claim, it had to decide if the DeGcmno doctrine barred it from considering appellant’s claim because he had admitted to the offense during the punishment phase.6

After a lengthy discussion of the development of the DeGamo/Leday doctrine, the court of appeals concluded that no case directly addresses that doctrine’s application to a claim that the State struck at defendant over the shoulders of counsel.7 The court then analyzed “the treatment of this type of error in other contexts” to see if the State’s argument could be said to implicate a “fundamental right” under Le-day.8 After a second lengthy discussion, the court concluded that this type of closing-argument error “does not implicate fundamental rights, and, thus, is not in the category of error that would survive for our review under Leday after appellant confessed to having committed the offense.” 9 After three pages of detailed legal analysis, the court of appeals finally determined that it could not address the merits of appellant’s claim of improper jury argument. It affirmed the trial court judgment.10

II.

Although the judicially created DeGar-mo doctrine derived its name from a particularly grisly capital-murder case,11 the *199core of the doctrine had been a part of Texas criminal jurisprudence for many years before that. In DeGarmo, this Court held that a defendant who testifies at the punishment stage of trial and admits his guilt to the crime for which he had been found guilty waives any challenge to the sufficiency of the evidence.12 We noted, “The law as it presently exists is clear that such a defendant not only waives a challenge to the sufficiency of the evidence, but he also waives any error that might have occurred during the guilt stage of the trial.”13 Whether that was the “law as it presently existed” at that time,14 the so-called DeGarmo doctrine was solidified in McGlothlin v. State15 In that 1995 case, Judge Baird characterized the doctrine as holding that “the judicial confession at punishment waives all error that occurred at the guilt stage of the trial.”16

The DeGarmo doctrine was originally built upon the notion that “[i]t would be an exercise in futility to reverse” a case for insufficient evidence when the defendant testified at punishment and admitted his guilt because his testimony “could be used against him on a retrial.”17 A second jury would necessarily convict the defendant based on his former testimony, so it would be a waste of time and effort to require a retrial in which the evidence clearly would be sufficient. But that rationale for the rule disappeared when the United States Supreme Court held that, if an appellate court finds the evidence insufficient to support the defendant’s conviction, double-jeopardy principles bar a retrial.18 Except for the hoary doctrine of stare decisis, this was the only rationale for the unique Texas rule.19

*200Under the DeGarmo waiver doctrine, if the defendant testified at the punishment stage and admitted to committing the criminal offense, then it did not matter how egregiously unfair or unconstitutional the guilt portion of the trial was. If the defendant’s confession were the product of physical or psychological torture, it would not matter that the trial judge admitted it in violation of the Sixth Amendment. If the police battered down the defendant’s door, beat him up, and searched his home over his vehement protests, it was of no importance that the trial judge admitted the illegally seized evidence in violation of the Fourth Amendment. If the trial judge flagrantly violated the rules of evidence and procedure, too bad. If the defendant admitted his guilt during the punishment phase, he automatically waived appellate review of all errors — great and small — at the guilt stage.

The “waiver” holding in DeGarmo was overturned by this Court in Leday v. State.20 Indeed, Leday jettisoned much of the DeGarmo doctrine as having been built upon a false premise of ensuring accuracy because trials are not merely a search for “truth.” They are also a societal exemplar of “fair play.”21

Our criminal justice system makes two promises to its citizens: a fundamentally fair trial and an accurate result. If either of those two promises are not met, the criminal justice system itself falls into disrepute and will eventually be disregarded.22

The DeGarmo doctrine may arguably serve the interest of an accurate result at the guilt stage, but it may also negate the equally important societal goal of a fair trial. And, at the sentencing stage, it negates the interest in accuracy.23 This Court recognized that problem in Leday and therefore rejected the applicability of the DeGarmo “waiver” doctrine to a laundry list of various constitutional and other substantive or procedural guarantees.24

*201These guarantees were too important to be “waived” merely because the defendant had admitted his guilt in a different stage of the proceedings.25

Our criminal-justice system depends upon trial judges making correct legal rulings. Our laws provide for appellate review of those rulings to ensure that our system will deliver accurate results in a fair proceeding.26 Indeed, that is the rationale for permitting a defendant to plead guilty with a plea bargain, yet appeal the correctness of judicial rulings on pretrial motions. For example, a defendant might obtain an adverse ruling on a pretrial Daubert27 hearing on the scientific accuracy of a novel polygraph procedure, and, based upon the inevitability of the polygraph results coming into evidence, plead guilty but appeal the trial judge’s ruling on the polygraph results.28 The *202DeGarmo doctrine, even as it exists post-Leday, strips away any right to judicial review of the admission of “junk science” evidence because the defendant, although he had precisely the same pretrial hearing and ruling, testified at the punishment stage and admitted guilt.29

The defendant who pleads guilty should not be treated more favorably in the appellate review of legal rulings than the defendant who went to trial but had the temerity to testify truthfully at the punishment phase. In the latter case, a defendant must give up his Sixth Amendment right to a trial by jury or his Fifth Amendment right to testify to ensure appellate review of the trial judge’s “junk science” pretrial ruling. This trade-off of constitutional rights invokes the same “cruel trilemma” concerns that Judge Womack addressed in Leday.30

This Court, in Leday, noted that the DeGarmo doctrine has practical consequences only when the trial judge commits reversible error.31 Thus, if the defendant would not have prevailed on the merits of his appellate claim and he would not otherwise have been entitled to a new trial, then the DeGarmo doctrine makes no difference at all.32 To alleviate the unfairness of this *203position, the Court, in Leday, separated procedural rights into two groups — those too important to be “waived” by the De-Garmo doctrine33 and those not quite so important, to which DeGarmo waiver would continue to apply — the “great” rights and the “small” rights.

According to the court of appeals in this case, the right to a trial not infected with a prosecutorial closing argument that would otherwise be reversible error34 is not an important right. It is just a “small” right and does not fall within the Leday ambit of protected procedural rights.35 Reversible error for “small” rights is waived under the DeGarmo doctrine. This dichotomy does not make sense. Reversible error is reversible error, regardless of the character of the right being substantially gouged. As Judge Meyers explained in his McGlothlin dissent: When the unfairness occurs during the guilt stage of a trial, “no legitimate interest of the system is served by holding that [the defendant’s admission of guilt during the punishment phase] somehow ratified the unfairness.”36

Furthermore, the “cruel trilemma” rationale for rejecting application of the De-Garmo doctrine in Leday applies with equal force in cases in which the defendant elaims non-fundamental or non-constitutional error on appeal. As Judge Womack explained in Leday, a defendant who has been found guilty faces a “cruel trilemma” in deciding whether to testify and admit guilt at punishment.37 If he admits guilt, he waives error under DeGarmo; if he denies guilt, he is exposed to aggravated perjury charges and increased punishment; if he does not testify, he loses the opportunity to give the sentencer information that only he possesses.38 As a practical matter, every defendant who has been *204found guilty faces this “cruel trilemma” decision and the DeGarmo doctrine has an outsized impact upon the defendant’s decision-making because his counsel cannot accurately predict, at the time the decision to testify must be made, whether potential appellate claims might be waived under the last vestiges of the DeGarmo doctrine. Thus, while the DeGarmo doctrine may be said to serve the interest of accuracy at the guilt-stage of trial, it disserves that very same interest at the punishment stage, and it disserves the interest in the “fairness” of the trial at both stages.39

We do not need the DeGarmo doctrine,40 just as we did not need the judicially created Helms waiver rule.41 We have not relied upon the DeGarmo doctrine even once in the fourteen years since we severely limited it in Leday.42 If a trial judge’s legal ruling is wrong, appellate courts should address that legal ruling (if properly preserved by objection) and explain why it is wrong. But if that ruling did not “affect substantial rights,”43 ie., it did not seriously affect the verdict or render the trial fundamentally unfair, then it is deemed harmless. The harmless-error rule, not the DeGarmo doctrine, protects the criminal-justice system from unwarranted or undeserved reversals for improper closing arguments.44

For these reasons we extend the reasoning and analysis set out in Leday to all rights, great and small, and give the De-Garmo doctrine the burial it so richly deserves. We reverse the judgment of the court of appeals and remand this case to that court for consideration of the merits of appellant’s sole claim.

filed a dissenting opinion in which KELLER, P.J., and KEASLER, J., joined.

In this case we have been asked to determine whether Leday v. State’s1 exceptions to DeGarmo v. State2 should be extended to a broader class of guilt-phase errors. The Court says that they should be extended to all errors. As the author of the Leday opinion, I respectfully disagree.

I agree with learned commentators that the application of the DeGarmo doctrine should consider the values that underlie the law that the trial court failed to follow.

As Leday suggested, the crux of the ... issue is the extent to which reliable assurance that the convicted defendant is guilty justifies barring that defendant from raising claims of error in the guilt-innocence determination. Leday relied heavily upon the conclusion that claims of error often enough invoked values other than trial accuracy to require a conclusion that such admissions never justify preclusion of this sort. This conclusion is questionable. Leday never carefully identified what values are served by appellate review of various claims of error or explained how preclusion of such review would affect the law’s ability to pursue these values.

The rule barring use of a reliable but involuntary confession is, as Leday indicated, a rule that serves objectives other than the accuracy of the outcome of the trial. Would barring defendants who admit guilt at punishment from seeking relief from use of such confessions at the guilt trials impair the ability of the law to implement those values? If all that is at issue is the need to discourage judges from erroneously admitting such confessions, perhaps barring guilty appellants from obtaining review would not impair the deterrent effect of appellate review in general. But perhaps a guilty defendant whose guilt trial was tainted by the use of such a confession is entitled to personal relief in order to implement these other values.

Despite its extensive discussion, Le-day arguably failed to come to grips with the real issue underlying the DeGarmo [sic ] Doctrine.3

Today the Court not only omits such a thoughtful consideration, but delivers dicta that seek to foreclose even the possibility of undertaking such consideration in the future. We should welcome the possibility of building on Leday.

As for this case, I agree with the Court of Appeals that the prosecutor’s argument to the jury is not in the class of errors to which Leday applies. It is not included in Leday ’s list of violations, and the appellant has not argued any due-process concerns or fundamental individual rights that should override the truth-finding function of the trial. That the State criticized defense counsel’s argument as one that was twisting and turning and filling in the holes to make it work was not a constitutional violation that put the appellant in the “cruel trilemma” which we addressed in Leday.4 I would hold that the courts *206below did not err in finding that the appellant’s complaint was forfeited.