Juan Carlos Reyna v. State

Summary

The Fourteenth Court of Appeals of Texas affirmed Juan Carlos Reyna’s murder conviction. The court held that the trial court did not err by omitting a jury instruction presuming the reasonableness of deadly force because the evidence conclusively showed that Reyna was engaged in criminal activity, namely cocaine possession, when he used deadly force. The court also concluded that the evidence supported the other conditions for the presumption but not the condition requiring that the defendant not be engaged in criminal activity.

Holdings

1. The trial court was not required to submit the statutory presumption-of-reasonableness instruction because the evidence conclusively established that Reyna was engaged in criminal activity when he used deadly force.
2. The omission did not constitute reversible error because the instruction was not the law applicable to the case; even if Reyna had specifically requested it, the trial court would not have erred by omitting it.

Questions Presented

1. Whether the trial court erred by omitting a jury instruction presuming that Reyna's belief in the necessity of deadly force was reasonable.
2. Whether the evidence conclusively established that Reyna was engaged in criminal activity at the time he used deadly force, thereby defeating the statutory presumption of reasonableness.

Disposition

affirmed