Summary
The Second Court of Appeals of Texas affirmed Christon L. Jackson’s conviction for felony murder and seventy-year sentence. The court held that the evidence was legally sufficient to show that Jackson caused the victim’s fatal head injury during a robbery, rejecting his theory that a later injury caused the death. The court also upheld the exclusion of defense exhibits concerning an accomplice witness’s criminal history, concluding that the evidence was either not logically connected to alleged bias or was cumulative and harmless.
Holdings
- The evidence was legally sufficient to support the finding that, during the robbery, Jackson inflicted the blunt-force head injury that caused Farid's death.
- The trial court did not abuse its discretion or violate the Confrontation Clause by excluding the three defense exhibits concerning Washington's older family-violence charges and related documents.
Questions Presented
- Whether the evidence was legally sufficient to prove that Jackson caused Farid's death by committing an act clearly dangerous to human life during the robbery.
- Whether the trial court violated Jackson's Sixth Amendment Confrontation Clause rights by excluding defense exhibits offered to show accomplice witness Maurice Washington's bias.
Disposition
affirmed
Cases Cited (36)
- Jackson v. Virginia, 443 U.S. 307, 319 (1979)(followed)
- Queeman v. State, 520 S.W.3d 616, 622 (Tex. Crim. App. 2017)(followed)
- Harrell v. State, 620 S.W.3d 910, 914 (Tex. Crim. App. 2021)(followed)
- Martin v. State, 635 S.W.3d 672, 679 (Tex. Crim. App. 2021)(followed)
- Braughton v. State, 569 S.W.3d 592, 608 (Tex. Crim. App. 2018)(followed)
- Villa v. State, 514 S.W.3d 227, 232 (Tex. Crim. App. 2017)(followed)
- Carter v. State, 620 S.W.3d 147, 149 (Tex. Crim. App. 2021)(followed)
- Zuniga v. State, 551 S.W.3d 729, 739 (Tex. Crim. App. 2018)(followed)
- Tate v. State, 500 S.W.3d 410, 413 (Tex. Crim. App. 2016)(followed)
- Temple v. State, 390 S.W.3d 341, 363 (Tex. Crim. App. 2013)(followed)
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