Colette Angela Richnow v. State

CourtCourt of Appeals of Texas
DecidedDecember 3, 2008
Docket09-07-00366-CR
StatusPublished

This text of Colette Angela Richnow v. State (Colette Angela Richnow 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
Colette Angela Richnow v. State, (Tex. Ct. App. 2008).

Opinion

In The



Court of Appeals



Ninth District of Texas at Beaumont

____________________



NO. 09-07-366 CR



COLETTE ANGELA RICHNOW, Appellant



V.



THE STATE OF TEXAS, Appellee



On Appeal from the 410th District Court

Montgomery County, Texas

Trial Cause No. 06-09-09387-CR



MEMORANDUM OPINION

Colette Angela Richnow challenges the legal and factual sufficiency of the evidence supporting her conviction and life sentence for two counts of capital murder. Richnow argues the State failed to prove that Richnow was present at the victims' home when the murders occurred or that she solicited, encouraged, aided, or directed Terry Wilkerson to commit the murders in the course of committing a burglary of a habitation. The State argues Richnow is criminally responsible for the murders committed by Wilkerson, either because she committed the offenses, aided Wilkerson in the commission of the offenses, or Richnow was a conspirator in the commission of the burglary and the murders were committed by Wilkerson in furtherance of the burglary.

In assessing the legal sufficiency of the evidence to support a criminal conviction, we consider all the evidence in the light most favorable to the verdict and determine whether, based on that evidence and reasonable inferences therefrom, a rational juror could have found the essential elements of the crime beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 318-19, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979); Powell v. State, 194 S.W.3d 503, 506 (Tex. Crim. App. 2006); Guevara v. State, 152 S.W.3d 45, 49 (Tex. Crim. App. 2004). The reviewing court must give deference to "the responsibility of the trier of fact to fairly resolve conflicts in testimony, to weigh the evidence, and to draw reasonable inferences from basic facts to ultimate facts." Jackson, 443 U.S. at 318-19, 99 S.Ct. 2781. In reviewing the sufficiency of the evidence, we should look at "events occurring before, during and after the commission of the offense and may rely on actions of the defendant which show an understanding and common design to do the prohibited act." Cordova v. State, 698 S.W.2d 107, 111 (Tex. Crim. App. 1985). Each fact need not point directly and independently to the guilt of the appellant, as long as the cumulative force of all the incriminating circumstances is sufficient to support the conviction. See Johnson v. State, 871 S.W.2d 183, 186 (Tex. Crim. App. 1993) ("[i]t is not necessary that every fact point directly and independently to the defendant's guilt; it is enough if the conclusion is warranted by the combined and cumulative force of all the incriminating circumstances."); Barnes v. State, 876 S.W.2d 316, 321 (Tex. Crim. App. 1994); Alexander v. State, 740 S.W.2d 749, 758 (Tex. Crim. App. 1987). Circumstantial evidence is as probative as direct evidence in establishing the guilt of an actor, and circumstantial evidence alone can be sufficient to establish guilt. Guevara, 152 S.W.3d at 49. On appeal, the same standard of review is used for both circumstantial and direct evidence cases. Id.



Hooper v. State, 214 S.W.3d 9, 13 (Tex. Crim. App. 2007).



In addressing a factual sufficiency claim, we review the evidence in a neutral light rather than the light most favorable to the verdict. Evidence is factually insufficient if the evidence supporting the verdict is so weak that the verdict seems clearly wrong and manifestly unjust, or if the supporting evidence is outweighed by the great weight and preponderance of the contrary evidence so as to render the verdict clearly wrong and manifestly unjust. We do not reverse for factual insufficiency if the greater weight and preponderance of the evidence actually favors conviction.



Neal v. State, 256 S.W.3d 264, 275 (Tex. Crim. App. 2008), petition for cert. filed, (U.S. Sept. 16, 2008) (No. 08-6413) (footnotes omitted). In conducting a factual-sufficiency analysis, we must be cognizant of the fact that a jury has already passed on the facts and must give due deference to the determinations of the jury. See Lancon v. State, 253 S.W.3d 699, 704-05 (Tex. Crim. App. 2008).

Both legal and factual sufficiency standards require the reviewing court to consider all of the evidence. "The difference between the two standards is that the former requires the reviewing court to defer to the jury's credibility and weight determinations while the latter permits the reviewing court to substitute its judgment for the jury's on these questions 'albeit to a very limited degree.'" In reality, a "factual-sufficiency review is 'barely distinguishable' from a Jackson v. Virginia legal sufficiency review."



Rollerson v. State, 227 S.W.3d 718, 724 (Tex. Crim. App. 2007)(footnotes omitted).



The jury charges in this case authorized the jury to find Richnow guilty of capital murder if she acted as a principal, as a party under Section 7.02(a) of the Penal Code, or as a conspirator under Section 7.02(b) of the Penal Code. See Tex. Pen. Code Ann. § 7.02(a), (b) (Vernon 2003). A person is criminally responsible for an offense committed by the conduct of another if, acting with intent to promote or assist the commission of the offense, she solicits, encourages, directs, aids, or attempts to aid the other person to commit the offense. Id. § 7.02(a)(2). Further, if "[i]n the attempt to carry out a conspiracy to commit one felony, another felony is committed by one of the conspirators, all conspirators are guilty of the felony actually committed, though having no intent to commit it, if the offense was committed in furtherance of the unlawful purpose and was one that should have been anticipated as a result of the carrying out of the conspiracy." Id. § 7.02(b). The verdict of guilt will be upheld if the evidence is sufficient on any of the three theories of criminal responsibility submitted to the jury in the charge. See Sorto v. State, 173 S.W.3d 469, 472 (Tex. Crim. App. 2005).

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Sorto v. State
173 S.W.3d 469 (Court of Criminal Appeals of Texas, 2005)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Guevara v. State
152 S.W.3d 45 (Court of Criminal Appeals of Texas, 2004)
Johnson v. State
871 S.W.2d 183 (Court of Criminal Appeals of Texas, 1993)
Brewer v. State
852 S.W.2d 643 (Court of Appeals of Texas, 1993)
Alexander v. State
740 S.W.2d 749 (Court of Criminal Appeals of Texas, 1987)
Rector v. State
738 S.W.2d 235 (Court of Criminal Appeals of Texas, 1986)
Rollerson v. State
227 S.W.3d 718 (Court of Criminal Appeals of Texas, 2007)
Escobar v. State
28 S.W.3d 767 (Court of Appeals of Texas, 2000)
Lancon v. State
253 S.W.3d 699 (Court of Criminal Appeals of Texas, 2008)
Cordova v. State
698 S.W.2d 107 (Court of Criminal Appeals of Texas, 1985)
O'Pry v. State
642 S.W.2d 748 (Court of Criminal Appeals of Texas, 1982)
Powell v. State
194 S.W.3d 503 (Court of Criminal Appeals of Texas, 2006)
Johnson v. State
6 S.W.3d 709 (Court of Appeals of Texas, 1999)
Neal v. State
256 S.W.3d 264 (Court of Criminal Appeals of Texas, 2008)
Madden v. State
799 S.W.2d 683 (Court of Criminal Appeals of Texas, 1990)
Barnes v. State
876 S.W.2d 316 (Court of Criminal Appeals of Texas, 1994)

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