Bradford Allen Thompson v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 14, 2025
Docket07-24-00082-CR
StatusPublished

This text of Bradford Allen Thompson v. the State of Texas (Bradford Allen Thompson v. the State of Texas) 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
Bradford Allen Thompson v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-24-00082-CR

BRADFORD ALLEN THOMPSON, APPELLANT

V.

THE STATE OF TEXAS, APPELLEE

On Appeal from the 46th District Court Wilbarger County, Texas Trial Court No. 12,896, Honorable Cornell Curtis, Presiding

March 14, 2025 MEMORANDUM OPINION Before QUINN, C.J., and DOSS and YARBROUGH, JJ.

Appellant, Bradford Allen Thompson, appeals from his conviction of murder and

resulting life sentence.1 He raises six issues regarding evidentiary rulings, jury selection,

and jury instructions. After careful consideration of the record and applicable law, we

affirm the trial court’s judgment.

1 See TEX. PENAL CODE ANN. § 19.02(b)(1), (c) (felony of the first degree). Background

In November 2022, Appellant was indicted for intentionally and knowingly causing

the death of Andre Sandoval by shooting him with a firearm. Prior to trial, Appellant filed

a motion to suppress evidence obtained during a warrantless search of his front yard,

which the trial court denied after a hearing. In December 2023, a three-day jury trial was

held.

The State’s witnesses provided a detailed account of the shooting. On the evening

of October 11, 2022, multiple witnesses observed Sandoval2 sitting on a curb on Deaf

Smith Street in Vernon, Texas. Witnesses heard a single “heavy” gunshot followed by

rapid gunfire. The “heavy” gunshot was believed to be from a shotgun or rifle. One

witness observed Appellant place a shotgun on the ground, pull out a pistol, and shoot

rounds into Sandoval while standing over him. When the first pistol was empty, Appellant

drew a second pistol and continued firing while Sandoval attempted to crawl away.

Despite neighbors calling for him to stop, Appellant continued shooting until he had

emptied the second pistol, with Sandoval attempting to curl into a protective ball. In all,

testimony showed that Sandoval died from 31 gunshot entrance wounds. Appellant told

a neighbor he shot Sandoval because “I was tired of him being there.”

After the shooting, Appellant walked to his residence, placed the shotgun on a

bench in his front yard, and put the two pistols in the bed of his pickup truck. He then

2 Sandoval was about five-and-a-half feet tall and 112 pounds. Often, he was seen walking around town.

2 removed his shirt, lit a cigarette, and walked to the sidewalk with his hands raised above

his head. Police arrived shortly thereafter and placed him under arrest.

Appellant’s wife, Sarahrae Thompson, testified during the punishment phase of

trial. She testified that for approximately four months before, Sandoval had been “lurking,”

and sitting on curbs throughout their neighborhood near her home.3 He would sometimes

pace, mumble, and lie on the grass. Mrs. Thompson was particularly uncomfortable when

Sandoval would sit across the street watching her grandchildren play; a medical condition

prevented her from defending herself and the children. She testified that Appellant was

aware of her concerns and that they had called the police multiple times regarding

Sandoval. According to her testimony, officers advised them that Sandoval was not

breaking any law and there was nothing they could do to remove him. Following

Appellant’s arrest, he said during a jailhouse telephone call with his wife, “I took care of

the problem.”

Analysis

Issue One: Exclusion of Justification Evidence During Guilt Phase

In his first issue, Appellant argues the trial court erred by excluding testimony that

Sandoval had a criminal history and may have uttered the word “gun” while near

Appellant’s residence three days before the shooting.4 Appellant contended this evidence

3 According to Mrs. Thompson, Sandoval was never observed entering onto their property.

4 Mrs. Thompson’s testimony outside the jury’s presence indicated that while she and Appellant

were unloading groceries from their vehicle, Sandoval approached the corner nearby. She heard him say the word “gun.” She turned to her husband and asked, “Did he say gun?” Her husband responded by asking, “Does he have a gun?” She replied that she did not know and suggested they quickly take their groceries inside the house.

3 was relevant to establishing that he had a reasonable belief that he needed to use deadly

force to defend himself, his wife, or his grandchildren. The trial court ruled that in the

absence of some evidence that Sandoval used or attempted to use unlawful force at or

near the time of the shooting, the testimony was irrelevant, as well as more prejudicial

than probative.

We review a trial court’s decision to admit or exclude evidence for an abuse of

discretion. Martinez v. State, 327 S.W.3d 727, 736 (Tex. Crim. App. 2010). We will not

reverse the trial court’s ruling unless it is so clearly wrong as to lie outside the zone within

which reasonable people might disagree. Taylor v. State, 268 S.W.3d 571, 579 (Tex.

Crim. App. 2008).

Our analysis begins with determining whether the excluded evidence was relevant

to the issues at trial. Evidence is relevant if it has any tendency to make the existence of

any fact that is of consequence to the determination of the action more or less probable

than it would be without the evidence. TEX. R. EVID. 401. For evidence to be relevant, it

must be both material and probative. Miller v. State, 36 S.W.3d 503, 507 (Tex. Crim. App.

2001). The Court of Criminal Appeals has explained that if no “issue” in the case could

be influenced by the proffered evidence, then it is irrelevant and thus inadmissible.

Henley v. State, 493 S.W.3d 77, 82 (Tex. Crim. App. 2016).

Appellant asserts the excluded evidence was relevant to justification defenses

such as self-defense and defense of a third party. This requires evidence that a person

reasonably believes the conduct “is immediately necessary” to avoid imminent harm. See

4 TEX. PENAL CODE ANN. § 9.31(a) (self-defense); § 9.32(a) (defense of person). The critical

element in each of these defenses is the showing of an immediate threat or danger.5

In this case, the record contains no evidence that at the time of the shooting,

Sandoval engaged in any aggressive conduct or presented any immediate threat to

Appellant or his family. The proposed testimony—that Sandoval uttered the word “gun”

three days before the shooting—does not establish any immediate threat or danger at the

time Appellant shot Sandoval. Given these circumstances, we conclude the trial court

did not abuse its discretion by excluding the evidence of Sandoval’s alleged utterance.

The first issue is overruled.

Issues Two and Three: Exclusion of Evidence and Denial of Instruction During Punishment Phase

In his second and third issues, Appellant contends the trial court erred during the

punishment phase by excluding evidence and denying a jury instruction regarding: (1)

Sandoval’s alleged “gun” statement, and (2) Appellant’s purported awareness of

Sandoval’s criminal history. Appellant argues this evidence was relevant to whether he

acted under the immediate influence of sudden passion arising from adequate cause

when he shot Sandoval.

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