Erin Ashlyn Moffatt v. State

CourtCourt of Appeals of Texas
DecidedJune 30, 2011
Docket01-10-00310-CR
StatusPublished

This text of Erin Ashlyn Moffatt v. State (Erin Ashlyn Moffatt 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
Erin Ashlyn Moffatt v. State, (Tex. Ct. App. 2011).

Opinion

Opinion issued June 30, 2011

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-10-00310-CR

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Erin Ashlyn Moffatt, Appellant

V.

The State of Texas, Appellee

On Appeal from the 405th District Court

Galveston County, Texas

Trial Court Case No. 08CR3041

MEMORANDUM OPINION

          A jury found Erin Ashlyn Moffatt guilty of the first degree felony offense of murder of her mother, Jana Moffatt, and assessed punishment at 50 years’ confinement.[1]  On appeal, Erin contends that the evidence is legally insufficient to support the jury’s guilt finding because a fatal variance exists between the indictment and the evidence at trial.  Erin specifically asserts that the indictment alleges strangulation by use of a cord, but that the evidence at trial indicated strangulation by hand as the cause of death. 

We affirm.

Background

Dina Sparkman, Jana’s sister, reported Jana missing to police.  Seven days later and two days after Hurricane Ike made landfall in the surrounding area, officers from the Brazoria County Sherriff’s Department discovered a body in an open field.  A plastic trash bag had been tied over a portion of the body which had undergone significant decomposition.  In the days before reporting her sister missing, Sparkman had repeatedly called Erin about Jana’s disappearance.  At one point, Erin asked Sparkman, “[W]hat do you want me to do? Go out there and look for my mother with a shovel.”  Erin did not respond when Sparkman questioned why she needed a shovel.

An officer with the League City Police Department went to the trailer Jana shared with Erin.  Erin told the officer that she had last seen her mother on September 2, when they had fought and Erin had refused to buy her mother methamphetamines.  Detective Beyer of the League City Police Department later took a formal statement from Erin, at which time she continued to deny any knowledge of her mother’s whereabouts.  Erin told Detective Beyer that while she did not know her mother’s location, she had a bad feeling and admitted that she told another person that she believed her mother was dead. 

Based on his interviews with Erin and several other subjects, Detective Beyer sought and received a search warrant for Erin’s trailer.  The officers seized several feet of carpet from the trailer that had a conspicuous red stain.  The day after officers executed the search warrant, Detective Beyer interviewed Michael Cory Lewis, Erin’s boyfriend at the time of her mother’s disappearance.  Lewis told Detective Beyer that Erin had strangled her mother and that he had helped her dispose of the body in a field.  Lewis accompanied Detective Beyer to the field where police found the body. 

Detective Beyer issued a warrant for Erin’s arrest.  Upon her arrest, Erin made a recorded confession to police that she had killed her mother.  Erin claimed to have blocked the incident from her memory, but stated that she had grabbed her mom and hurt her.  She stated, “I strangled my mom,” and when asked with what she stated, “A fing cord,” indentifying a white extension cord from the trailer.  She further stated, “I pulled this cord, and I don’t know what the hell . . . . I pulled it until she stopped breathing.”

She told police that Lewis had helped her by holding Jana down while Erin strangled her.  Believing that inserting air into a person’s blood stream killed them faster, Erin admitted that she stabbed her mother in the neck with a syringe.  Erin described how Jana bit her tongue almost completely off, causing her to bleed on the carpet.  After Jana stopped breathing, Erin stated they covered her head in a black trash bag, wrapped her in a rug, and loaded her into the trunk of a car.  They drove to an open grassy area and Lewis dumped Jana’s body. 

At trial, the medical examiner, Dr. Steven Pustilnik, testified that the body had decomposed significantly and that he could not discern any evidence of trauma from an external examination of the body.  Dr. Pustilnik, however, identified a fracture to the maxilla, which is the facial bone to the left of the nose, and a fracture to the hyoid bones, which are two bones in the neck or voice box.  Dr. Pustilnik testified that a break in the hyoid bones, which form a horseshoe shape, results from strangulation by squeezing the neck by hand.  When asked if strangulation by a cord or rope would cause this type of injury, Dr. Pustilnik responded:

A cord or rope generally does not, does not exert the pressure by moving the end of the hyoid this way and the end of the hyoid this way.  It is a circumferential ligature.  So, you see different injuries for those.  You see basically soft tissue injuries.  And you don’t see fractures of bones from a ligature [cord or similar strangulation method] being put around somebody’s neck.

Dr. Pustilnik went on to say that he “possibly” saw soft tissue injuries on the body, but could not be entirely sure because of the extent of decomposition.  Dr. Pustilnik also testified that the damage to the thyroid cartilage was caused by something sharp cutting across the voice box and that hypothetically a hypodermic needle could cause such an injury.

Dr. Joan Bytheway testified as a forensic anthropologist trained to identify injury patterns in skeletal remains.  Dr. Bytheway testified that the “number one cause of hyoid fractures is manual strangulation with the second cause being ligature strangulation [use of a cord or other instrument]. . . .”  Dr.

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Erin Ashlyn Moffatt v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/erin-ashlyn-moffatt-v-state-texapp-2011.