Caleb Rothlis v. The State of Texas

Summary

The Texas Court of Appeals for the Second District affirmed Caleb Rothlis’s convictions for aggravated assault with a deadly weapon, assault of a family or household member by impeding breath or circulation, and unlawful restraint. The court held that the trial court did not abuse its discretion under Texas Rule of Evidence 403 by admitting a 47-minute video of Rothlis threatening the complainant and her father under Texas Code of Criminal Procedure article 38.371. The court overruled Rothlis’s sole issue and affirmed the trial court’s judgments.

Holdings

1. Article 38.371(b) permits admission of relevant facts and circumstances, including evidence concerning the nature of the relationship between the defendant and complainant, in prosecutions involving offenses against a family or household member or dating partner.
2. The trial court did not abuse its discretion in admitting the video because its high probative value was not substantially outweighed by the danger of unfair prejudice or any other Rule 403 danger.

Questions Presented

1. Whether the trial court abused its discretion by admitting the forty-seven-minute video under Texas Code of Criminal Procedure article 38.371 when Rothlis argued that its probative value was substantially outweighed by the danger of unfair prejudice under Texas Rule of Evidence 403.

Disposition

affirmed