Angela Kuhn v. State

CourtCourt of Appeals of Texas
DecidedFebruary 7, 2008
Docket02-07-00157-CR
StatusPublished

This text of Angela Kuhn v. State (Angela Kuhn v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angela Kuhn v. State, (Tex. Ct. App. 2008).

Opinion

                                    COURT OF APPEALS

                                       SECOND DISTRICT OF TEXAS

                                                   FORT WORTH

                                                 NO. 2-07-157-CR

ANGELA KUHN                                                                                   APPELLANT

                                                             V.

THE STATE OF TEXAS                                                                                STATE

                                                       ------------

FROM COUNTY COURT AT LAW NO. 1 OF WICHITA COUNTY

MEMORANDUM OPINION[1]

I.  Introduction

Appellant Angela Kuhn appeals her conviction for assault by causing bodily injury to a family member.  In three issues, Kuhn argues that the trial court erred by denying her motion for directed verdict, denying her motion for mistrial, and improperly communicating with the jury during jury deliberations.  We will affirm.


II. Factual and Procedural Background

In the summer of 2004, Angela and her husband, Tim Kuhn, were separated, and Tim was living with his mother, Sharon Kuhn.  By court order, Sharon had temporary custody of the couple=s two children.  Angela had visitation rights and would pick up the children from and return the children to Sharon=s house. 

In September 2004, Angela picked up the children from Sharon=s house for her regular visitation and asked to speak with Tim.  Sharon told Angela that Tim was not at the house.  Angela, although angered, left.  At the end of her visitation that evening, Angela returned the children to Sharon=s house.  Angela again asked to speak with Tim. 

Both Angela and Sharon testified that, at this point, they had a physical altercation (the testimony, however, about who first attacked whom varied between the two women).  Sharon=s husband broke up the fight and called the police.  Angela left before the police arrived.


After making a police report, Sharon went to the emergency room for treatment of the injuries she had sustained in the fight.  Hospital records of Sharon=s emergency room visit along with pictures of Sharon=s injuries were admitted into evidence.  Likewise, Angela took a picture of the injuries she had sustained in the altercation, which the trial court also admitted into evidence at her request. 

After hearing all the evidence, the jury found Angela guilty of assaulting Sharon.  The trial court assessed Angela=s punishment at thirty days= confinement.  Angela now appeals.

III.  Jurisdiction

In her first issue, Angela argues that the trial court erred by overruling her motion for a directed verdict of acquittal based on the State=s purported failure to invoke the trial court=s jurisdiction by failing to prove that the offense occurred in the State of Texas. 

The State may establish a trial court=s jurisdiction by presenting circumstantial evidence that an element of the offense was committed in the state.  Vaughn v. State, 607 S.W.2d 914, 920 (Tex. Crim. App. 1980); Reger v. State, 598 S.W.2d 868, 871 (Tex. Crim. App. 1980).  In this case, both Angela and Sharon testified that the incident took place at Sharon=s residence.  Sharon testified that she lived at a specific address on Turtle Creek Road in Wichita Falls and that her residence was in Wichita County.  The hospital records of Sharon=s emergency room visit, which were admitted into evidence, also reflect that Sharon lived on Turtle Creek Road (the address was the same as that given in her testimony) in AWichita Falls, TX.@ 


Based on this testimony and written evidence, the jury could have reasonably concluded that the physical altercation between Sharon and Angela took place in AWichita Falls, TX,@ meaning in Texas.  See Vaughn, 607 S.W.2d at 920; Walker v. State, 195 S.W.3d 250, 257-58 (Tex. App.CSan Antonio 2006, no pet.) (holding that evidence that the offense occurred at a particular address in Guadalupe County was sufficient to establish jurisdiction in the state of Texas); James v. State, 89 S.W.3d 86, 89 (Tex. App.CCorpus Christi 2002, no pet.) (holding that evidence that the offense occurred in the city of Beaumont and Jefferson County was sufficient to circumstantially establish jurisdiction in Texas).  Accordingly, we overrule Angela

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Bluebook (online)
Angela Kuhn v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-kuhn-v-state-texapp-2008.