Jones, Steven Allen v. State

No. PD-1633-14 · Texas Court of Criminal Appeals · February 2, 2015 · No. PD-1633-14

Summary

This Texas Court of Criminal Appeals document concerns Steven Allen Jones's criminal appeal arising from a Harris County aggravated-assault conviction. The issues include the sufficiency of the evidence, the use of a deadly weapon, and whether the trial court should have instructed the jury on the lesser-included offense of assault.

Court
Texas Court of Criminal Appeals
Jurisdiction
Texas
Decision date
February 2, 2015
Docket number
PD-1633-14
Procedural posture
Petition for discretionary review from a judgment of the First Court of Appeals affirming a conviction for aggravated assault.
Standard of review
Whether the evidence supports submission of a lesser-included-offense instruction is reviewed under the two-step test requiring that the lesser offense be included within the proof necessary to establish the charged offense and that some evidence permit a rational jury to find the defendant guilty only of the lesser offense.
Precedential value
Unpublished or nonprecedential per curiam opinion; persuasive value may be limited under Texas appellate rules.
Parties
Steven Allen Jones v. State of Texas
Disposition
affirmed

Topics

lesser included offense instructionsjury instructionscriminal procedureappellate procedure

Practice areas

Texas criminal lawcriminal procedurejury instructionsaggravated assault

Questions Presented

  1. Whether the trial court erred by refusing to instruct the jury on assault as a lesser-included offense of aggravated assault.

Holdings

  1. The evidence did not entitle Jones to an instruction on the lesser-included offense of assault because it did not permit a rational jury to find him guilty of assault but not aggravated assault.

Factual background

Jones was charged with aggravated assault arising from an altercation involving an alleged deadly weapon. A jury convicted him of aggravated assault. Jones argued that the evidence required submission of assault as a lesser-included offense.

Procedural history

Jones was convicted in the 351st District Court of Harris County of aggravated assault. The First Court of Appeals affirmed. The Texas Court of Criminal Appeals considered Jones's challenge to the refusal to submit a lesser-included-offense instruction on assault and affirmed the judgment below.

Court Document

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