Cristian Escarcega v. the State of Texas

CourtCourt of Appeals of Texas
DecidedApril 17, 2025
Docket11-24-00008-CR
StatusPublished

This text of Cristian Escarcega v. the State of Texas (Cristian Escarcega 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
Cristian Escarcega v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

Opinion filed April 17, 2025

In The

Eleventh Court of Appeals __________

No. 11-24-00008-CR __________

CRISTIAN ESCARCEGA, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 161st District Court Ector County, Texas Trial Court Cause No. B-22-0009-CR

MEMORANDUM OPINION A jury found Appellant, Cristian Escarcega, guilty of the first-degree murder of Jesse Sanchez and assessed his punishment at life imprisonment in the Institutional Division of the Texas Department of Criminal Justice. See TEX. PENAL CODE ANN. § 19.02(b), (c) (West Supp. 2024). The trial court sentenced Appellant accordingly. In two issues, Appellant challenges the sufficiency of the evidence in support of his conviction and argues that the trial court abused its discretion in admitting an autopsy photograph where “the prejudicial value was great.” See TEX. R. EVID. 403. We affirm. Background On the evening of October 31, 2021, Officer Tyler Thelen with the Odessa Police Department (OPD) was working off duty as a security guard for a local bar when he heard gunshots originating from an adjacent parking lot. Officer Thelen approached the noise and saw “muzzle flashes” originating from two males standing beside a dark gray Nissan.1 At trial, Officer Thelen explained that the driver’s side door and front passenger door of the Nissan were both open, and the two men had been standing “halfway in and out of the vehicle,” respectively. The men then got into the Nissan and quickly drove away with the vehicle’s headlights off.2 Sanchez was later discovered lying face down underneath a white pickup, parked across from the initial location of the Nissan. Travis Fraser, a former patrol sergeant with the University of Texas System Police, testified that he was responding to the call of shots fired when he observed a gray Nissan pulling out of the parking lot with no headlights on, driving at a “very high rate of speed.” Sergeant Fraser immediately activated his lights and siren and pursued the vehicle. A chase ensued, reaching speeds of approximately 104 miles per hour. Sergeant Fraser testified that he never lost sight of the vehicle, and he was the lead officer in the pursuit until Ector County officials assumed control. A patrol officer with the Ector County Sheriff’s Office was in pursuit, and his dash camera recorded the Nissan slowing down on a dirt road moments before the

1 Officer Thelen’s body camera recording was admitted into evidence at trial, and Officer Thelen can be heard yelling out that a “dark gray Nissan” had just sped away. 2 Surveillance footage from a nearby bar captured the shooting from a distance.

2 vehicle’s two occupants jumped out of the vehicle and attempted to evade police on foot. Both men were apprehended shortly thereafter. The driver of the vehicle was identified as Martin Hernandez, and the passenger was identified as Appellant. Following Appellant’s arrest, his hands were swabbed for gunshot residue (GSR). Rebekah Lloyd, a forensic scientist with the Texas Department of Public Safety (DPS), testified that Appellant’s results were “consistent with either a person fir[ing] a weapon or being in the immediate proximity of a weapon that is being fired, or came in contact with a surface that had gunshot primer residue.” During Appellant’s attempted escape, Matt Muehlbrad, a former Ector County Sherriff’s Office patrol lieutenant, had remained with the abandoned Nissan. After ensuring that there was no one else inside the vehicle, Lieutenant Muehlbrad, along with other officers, located an armored vest, a 9-millimeter handgun, and an AR-15 rifle in the front-passenger-seat area. In the parking lot where the shooting occurred, officers recovered several projectiles, as well as seventeen 9-millimeter shell casings and fifteen .223 shell casings. Darrell Morgan, a firearms examiner with the DPS crime lab in Lubbock, confirmed that the projectiles and shell casings came from the firearms recovered in the Nissan. DPS Ranger Brian Burney testified that based on the location of the shell casings recovered and the known location of the vehicles involved, there were two shooters: one, utilizing a 9-millimeter handgun, who would have been standing outside the vehicle near the passenger side; and the other, using the AR-15, who was likely standing near the driver’s side. Ranger Burney further testified that it appeared that Sanchez had been ambushed as he was getting into his vehicle. As part of the investigation, OPD Detective James Santana reviewed surveillance footage from nearby bars and testified that Hernandez and Appellant had been waiting for thirty-three minutes in the parking lot before the shooting.

3 Dr. Luisa Florez, a forensic pathologist, performed the autopsy on Sanchez. Dr. Florez explained that although Sanchez had been shot several times, sustaining gunshot wounds to his right forearm, left shoulder, and right thigh, the cause of death was “blood loss due to the injuries of the left iliac.” The bullet projectile severed an internal blood vessel that caused the death of Sanchez. Dr. Florez additionally opined that two different types of weapons had been used in the shooting: a “high velocity rifle” believed to have caused the lethal injury, and a handgun that caused the injuries on Sanchez’s arms and shoulder. Twenty-four autopsy photographs were admitted into evidence depicting Sanchez’s various injuries. At the close of evidence, the jury was instructed on the law of parties. The jury found Appellant guilty of murder as charged in the indictment and assessed his punishment at life imprisonment. This appeal followed. Sufficiency of the Evidence Appellant first argues the evidence is insufficient to support his conviction for murder. Specifically, he contends that the State failed to establish that he was the person who shot Sanchez. A. Standard of Review We review a challenge to the sufficiency of the evidence, regardless of whether it is framed as a legal or factual sufficiency challenge, under the standard of review set forth in Jackson v. Virginia, 443 U.S. 307 (1979). See Brooks v. State, 323 S.W.3d 893, 912 (Tex. Crim. App. 2010); Polk v. State, 337 S.W.3d 286, 288– 89 (Tex. App.—Eastland 2010, pet. ref’d). In reviewing the sufficiency of the evidence to support a conviction, we must “consider the evidence in the light most favorable to the verdict and determine whether, based on the evidence and reasonable inferences therefrom, a rational juror could have found that the State has proven the essential elements of the crime beyond a reasonable doubt.” Baltimore v.

4 State, 689 S.W.3d 331, 341 (Tex. Crim. App. 2024) (citing Jackson, 443 U.S. at 319). “This familiar standard gives full play to the responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence, and to draw reasonable inferences from basic facts to ultimate facts.” Edward v. State, 635 S.W.3d 649, 655 (Tex. Crim. App. 2021) (quoting Jackson, 443 U.S. at 319). Therefore, “[i]f the record supports conflicting inferences, the reviewing court must ‘presume that the factfinder resolved the conflicts in favor of the prosecution’ and defer to the jury’s factual determinations.” Garcia v. State, 667 S.W.3d 756, 762 (Tex. Crim. App. 2023) (quoting Wise v. State, 364 S.W.3d 900, 903 (Tex. Crim. App. 2012)). “[A] reviewing court does not sit as a thirteenth juror and may not substitute its judgment for that of the factfinder by reevaluating the weight and credibility of the evidence.” Id. (quoting Isassi v. State, 330 S.W.3d 663, 638 (Tex. Crim. App. 2010)); see TEX. CODE CRIM. PROC. ANN.

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