Christopher Morrison v. The State of Texas

Summary

The Fourth Court of Appeals of Texas affirmed Christopher Morrison’s convictions for two misdemeanor counts of deadly conduct. Morrison argued that the evidence was legally insufficient to prove that his BB gun placed the complainants in imminent danger of serious bodily injury. The court held that the BB gun’s tested velocity, the owner’s manual, the distance involved, and evidence of projectile impacts supported the jury’s finding.

Holdings

1. The evidence was legally sufficient for a rational jury to find that Morrison's BB gun was capable of causing serious bodily injury and therefore to support the two deadly-conduct convictions.
2. The court did not separately address Morrison's factual-sufficiency argument because Texas criminal appellate courts apply the Jackson legal-sufficiency standard rather than a separate factual-sufficiency standard.

Questions Presented

1. Whether the evidence was legally sufficient to support Morrison's two misdemeanor deadly-conduct convictions, particularly whether the BB gun was capable of causing serious bodily injury.
2. Whether the evidence was factually sufficient to support the convictions.

Disposition

affirmed