Daveon Demonta Woods v. State

Summary

The Sixth Court of Appeals of Texas affirmed Daveon Demonta Woods’s conviction for capital murder and life sentence without parole. The court held that the trial court did not abuse its discretion in denying a mistrial based on courtroom outbursts or admitting challenged photographs and body-camera footage. The court also held that Woods forfeited his complaint concerning the lack of a jury-panel shuffle.

Holdings

1. The trial court did not abuse its discretion in denying the mistrial because Woods failed to show a reasonable probability that the bystanders' conduct interfered with the jury's verdict, and the jury was instructed to disregard the non-evidentiary event.
2. The trial court did not abuse its discretion in admitting the photographs or the body-camera recording because their probative value was not substantially outweighed by the danger of unfair prejudice.
3. Woods forfeited his complaint about the lack of a jury-panel shuffle because he expressly declined a shuffle and presented no argument or authority supporting the asserted error.

Questions Presented

1. Whether the trial court abused its discretion by denying Woods's request for a mistrial based on emotional outbursts in and near the courtroom.
2. Whether the trial court abused its discretion by admitting photographs of the victim with his family and a brief body-camera recording depicting the shooting's aftermath under Texas Rule of Evidence 403.
3. Whether Woods preserved a complaint that the trial court failed to sua sponte shuffle the jury panel.

Disposition

affirmed