Ryan Coleman v. the State of Texas

Summary

The Texas Fourteenth Court of Appeals reviewed Ryan Coleman’s conviction for aggravated sexual assault and his challenge to the admission of evidence concerning four alleged extraneous sexual assaults. The court held that the evidence was admissible under Texas Rules of Evidence 404(b) and 403, modified the judgment to delete an incorrect finding that Coleman waived his right to appeal, and affirmed the judgment as modified.

Holdings

1. The extraneous-offense evidence was admissible because it was relevant for a purpose apart from proving character conformity, including proving intent and rebutting the defensive theories of consent and fabrication.
2. The trial court did not abuse its discretion in determining that the probative value of the extraneous-offense evidence was not substantially outweighed by the danger of unfair prejudice.
3. The appellate court had authority to modify the trial court's judgment by deleting the incorrect special finding that Coleman waived his right to appeal.

Questions Presented

1. Whether the trial court abused its discretion under Texas Rules of Evidence 404(b) and 403 by admitting evidence of four alleged extraneous sexual assaults to show intent and rebut the defenses of consent and fabrication.

Disposition

affirmed