Felisha Lynn Scroggins v. the State of Texas

Court of Appeals of Texas·Decided December 8, 2025·No. 06-24-00235-CR·Published

Opinion

In the

Court of Appeals

Sixth Appellate District of Texas at Texarkana

No. 06-24-00235-CR

FELISHA LYNN SCROGGINS, Appellant V.

THE STATE OF TEXAS, Appellee

On Appeal from the 6th District Court Lamar County, Texas

Trial Court No. 30812

Before Stevens, C.J., van Cleef and Rambin, JJ.

Memorandum Opinion by Justice Rambin

MEMORANDUM OPINION

In late 2023, Felisha Lynn Scroggins and another individual were found to be housing Scroggins’s nine-year-old daughter, Alice,1 in a van in a parking lot. The three had been living in the van for about seven years. Scroggins was indicted, and a Lamar County jury convicted her of reckless injury to a child by act or omission, a second-degree felony, and assessed her punishment at twenty years’ incarceration. See TEX. PENAL CODE ANN. § 22.04 (Supp.). Scroggins claims the evidence was insufficient to prove that she recklessly committed any act or omission and was insufficient to prove Alice suffered a serious bodily injury. There was, however, testimony that years of insufficient nutrition had caused Alice’s growth to be stunted to the point that her size was that of a child four or five years younger than her actual age. When removed from Scroggins, Alice, who had never been to school, did not have the strength to walk from a classroom to a school cafeteria. While Alice’s mobility improved, there was testimony that she would suffer lasting physical and cognitive deficits compared to children of her chronological age. In other words, there was testimony sufficient to support a finding that Alice had suffered “bodily injury” due to years of malnutrition. There was also testimony from which the jury could conclude that Scroggins recklessly did that to Alice, whether by the acts of deliberate choices of withholding appropriate nutrition or the years-long omission of appropriate nutrition that, as a parent, Scroggins had the duty to provide. See TEX. FAM. CODE ANN. § 151.001(a)(3) (Supp.). Because we find the evidence was sufficient to support Scroggins’s conviction, we affirm.

1 We use a pseudonym to protect the identity of Scroggins’s daughter, who was a minor at the time of the offense. See TEX. R. APP. P. 9.10.

I. Standard of Review and Applicable Law “The due process guarantee of the Fourteenth Amendment requires that a conviction be supported by legally sufficient evidence.” Braughton v. State, 569 S.W.3d 592, 607 (Tex. Crim. App. 2018) (citing Jackson v. Virginia, 443 U.S. 307, 315–16 (1979)). “We assess legal sufficiency by viewing the evidence in the light most favorable to the verdict and asking whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Bittick v. State, 707 S.W.3d 366, 368 (Tex. Crim. App. 2024) (citing Jackson, 443 U.S. at 319). “We compare the trial evidence to ‘the elements of the offense as defined by a hypothetically correct jury charge for the case.’” Id. at 369 (quoting Zuniga v. State, 551 S.W.3d 729, 733 (Tex. Crim. App. 2018)).

“This familiar standard ‘recognizes the trier of fact’s role as the sole judge of the weight and credibility of the evidence after drawing reasonable inferences from the evidence.’” Braughton, 569 S.W.3d at 608 (quoting Adames v. State, 353 S.W.3d 854, 860 (Tex. Crim. App. 2011)). “On review, this Court determines whether the necessary inferences made by the trier of fact are reasonable, based upon the cumulative force of the evidence.” Id. (quoting Adames, 353 S.W.3d at 860). “We presume that the factfinder resolved any conflicting inferences in favor of the verdict, and we defer to that resolution.” Id. “As a reviewing court, we may not reevaluate the weight and credibility of the evidence in the record and thereby substitute our own judgment for that of the factfinder.” Id. “A reviewing court is thus ‘required to defer to the jury’s credibility and weight determinations.’” Id. (quoting Brooks v. State, 323 S.W.3d 893, 899 (Tex. Crim. App. 2010)). “However, juries are not permitted to come to conclusions based on ‘mere

speculation or factually unsupported inferences or presumptions.’” Id. (quoting Hooper v. State, 214 S.W.3d 9, 15 (Tex. Crim. App. 2007)).

“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.”’” Hammack v. State, 622 S.W.3d 910, 914 (Tex. Crim. App. 2021) (quoting Hooper, 214 S.W.3d at 13). “Each fact need not point directly and independently to the guilt of a defendant, as long as the cumulative force of all the incriminating circumstances is sufficient to support the conviction.” Walker v. State, 594 S.W.3d 330, 335 (Tex. Crim. App. 2020) (citing Hooper, 214 S.W.3d at 13). “Direct evidence and circumstantial evidence are equally probative, and circumstantial evidence alone may be sufficient to uphold a conviction so long as the cumulative force of all the incriminating circumstances is sufficient to support the conviction.” Ramsey v. State, 473 S.W.3d 805, 809 (Tex. Crim. App. 2015). Further, we “consider all of the admitted evidence, regardless of whether it was properly admitted.” Stahmann v. State, 602 S.W.3d 573, 577 (Tex. Crim. App. 2020) (citing Jackson, 443 U.S. at 319).

“To sustain a conviction for reckless injury to a child the evidence must prove that a defendant recklessly, by act or omission, caused serious bodily injury to a child.” 2 Williams v. State, 235 S.W.3d 742, 750 (Tex. Crim. App. 2007) (citing TEX. PENAL CODE ANN. § 22.04(a)(1)). In the context of injury to a child by omission, “the State’s burden [is] to show

2 Scroggins was indicted under Section 22.04(a)(1) of the Texas Penal Code: “FELISHA LYNN SCROGGINS, a parent of [Alice], . . . did then and there, by act or omission, intentionally and knowingly cause serious bodily injury to [Alice], a child 14 years of age or younger, by failing to provide adequate food or medical care.” See TEX. PENAL CODE ANN. § 22.04(a)(1).

that Appellant had a statutory duty to act, [s]he failed to act, and in failing to act, [s]he either: (1) intended serious bodily injury to be caused, or (2) knew serious bodily injury would be caused, but [s]he still failed to act.” Cockrell v. State, 721 S.W.3d 448, 454 (Tex. Crim. App. 2025). “A parent of a child has . . . the duty to support the child, including providing the child with clothing, food, shelter, medical and dental care, and education.” TEX. FAM. CODE ANN. § 151.001(a)(3). II. The Evidence at Trial Scroggins and Alice began living with Ramon Alvarez when Alice was three years old.

Scroggins said she had been “trying to find the Lord,” and when she saw Alvarez holding a cross on the side of the road, with “Jesus” on his van, she thought the Lord was giving her a message that “it was time to go.” Scroggins testified that she and Alice then moved into the van with Alvarez, and they traveled with Alvarez. They lived off donations Alvarez received as he preached the gospel. Throughout her testimony, Scroggins ascribed their comings and goings to divine directives given to Alvarez.3 Scroggins testified that a typical day in the van began with Alvarez getting up at 8:00 a.m., and she and Alice would get up at 9:00 a.m. They would get up, do prayers, Alice would brush her teeth, and then they would go to a gas station to get gas, fill jugs, and dump waste. Then they would set up somewhere where Alvarez would preach while Scroggins and

3 The following exchange between Scroggins’s counsel and Scroggins is illustrative:

Q: . . . [W]ho decided when to leave and where to go?

A: [Alvarez] did.

Q: And how did he know where to go or --

A. He would go and pray and then we’d just take off and the Lord would put us wherever he wanted us.

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