Grady Aaron Boyett v. the State of Texas

CourtCourt of Appeals of Texas
DecidedFebruary 2, 2022
Docket10-19-00209-CR
StatusPublished

This text of Grady Aaron Boyett v. the State of Texas (Grady Aaron Boyett 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
Grady Aaron Boyett v. the State of Texas, (Tex. Ct. App. 2022).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-19-00209-CR

GRADY AARON BOYETT, Appellant v.

THE STATE OF TEXAS, Appellee

From the 278th District Court Walker County, Texas Trial Court No. 28357

MEMORANDUM OPINION

The jury found Grady Aaron Boyett guilty of the offense of failure to register as a

sex offender, and the trial court assessed his punishment at twenty years in prison. Boyett

was sentenced accordingly. This appeal ensued. In a single issue, Boyett argues that a

material variance exists between the evidence presented at trial and the offense alleged

in the indictment. We will reverse and render a judgment of acquittal. Factual and Procedural Background

Boyett was charged by indictment with failing to comply with a specific provision

of the Sex Offender Registration Act. See TEX. CODE CRIM. PROC. ANN. arts. 62.001–62.408.

The indictment alleged that:

on or about the 8th day of March, 2017, and anterior to the presentment of this indictment, in the County and State aforesaid GRADY AARON BOYETT did then and there, while knowing that he was required to register with the local law enforcement authority in Walker County where the defendant resided or intended to reside for more than seven days, to wit: Walker County, because of a reportable conviction for Aggravated Sexual Assault, the defendant failed to register with the local law enforcement in Walker County. [Emphases added.]

After the jury found Boyett guilty, an agreement was reached for the State to

recommend to the trial judge a punishment of twenty years in prison. The trial judge

accepted the State’s punishment recommendation and assessed Boyett’s punishment

accordingly. The trial court certified Boyett’s right to appeal as to the guilt/innocence

phase only.

Issue

In his sole issue, Boyett contends that the evidence at trial is insufficient to support

his conviction because a material variance exists between the indictment and the evidence

presented at trial.

AUTHORITY

The Court of Criminal Appeals has expressed our standard of review of sufficiency

issues as follows: Boyett v. State Page 2 When addressing a challenge to the sufficiency of the evidence, we consider whether, after viewing all of the evidence in the light most favorable to the verdict, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 319, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979); Villa v. State, 514 S.W.3d 227, 232 (Tex. Crim. App. 2017). . . .

We measure whether the evidence presented at trial was sufficient to support a conviction by comparing it to “the elements of the offense as defined by the hypothetically correct jury charge for the case.” Malik v. State, 953 S.W.2d 234, 240 (Tex. Crim. App. 1997). The hypothetically correct jury charge is one that “accurately sets out the law, is authorized by the indictment, does not unnecessarily increase the State's burden of proof or unnecessarily restrict the State’s theories of liability, and adequately describes the particular offense for which the defendant was tried.” Id.; see also Daugherty v. State, 387 S.W.3d 654, 665 (Tex. Crim. App. 2013). The “law as authorized by the indictment” includes the statutory elements of the offense and those elements as modified by the indictment. Daugherty, 387 S.W.3d at 665.

Zuniga v. State, 551 S.W.3d 729, 732–33 (Tex. Crim. App. 2018).

A variance occurs when there is a discrepancy between the allegations in the

charging instrument and the evidence presented at trial. Johnson v. State, 364 S.W.3d 292,

294 (Tex. Crim. App. 2012). “In a variance situation, the State has proven the defendant

guilty of a crime but has proven its commission in a manner that varies from the

allegations in the charging instrument.” Gollihar v. State, 46 S.W.3d 243, 246 (Tex. Crim.

App. 2001).

In an evidentiary-sufficiency analysis, there are two types of variances: material

and immaterial variances. Thomas v. State, 444 S.W.3d 4, 9 (Tex. Crim. App. 2014). A

variance is material if it: (1) fails to adequately inform the defendant of the charge against

Boyett v. State Page 3 him or (2) subjects the defendant to the risk of being prosecuted later for the same crime.

Ramjattansingh v. State, 548 S.W.3d 540, 547 (Tex. Crim. App. 2018); Gollihar, 46 S.W.3d at

258. A sufficiency review does not rest on how the jury was instructed, but we review

whether the evidence supports the elements of the charged crime. Walker v. State, 594

S.W.3d 330, 335–36 (Tex. Crim. App. 2020). The elements of the charged crime are defined

by the hypothetically correct jury charge that accurately sets out the law, is authorized by

the indictment, does not unnecessarily increase the State’s burden of proof or

unnecessarily restrict the State’s theories of liability, and adequately describes the

particular offense for which the defendant was tried. Id. at 336. “As authorized by the

indictment” means the statutory elements of the offense as modified by the charging

instrument. Alfaro-Jimenez v. State, 577 S.W.3d 240, 244 (Tex. Crim. App. 2019). “Only

material variances will affect the hypothetically correct jury charge” and render the

evidence legally insufficient. Hernandez v. State, 556 S.W.3d 308, 312 (Tex. Crim. App.

2017). On the other hand, “[a]llegations giving rise to immaterial variances may be

disregarded in the hypothetically correct [jury] charge.” Gollihar, 46 S.W.3d at 257.

In addition to the foregoing, variances can occur in two different ways. Hernandez,

556 S.W.3d at 313. The first way—called a statutory variance—involves the statutory

language that defines the offense and occurs when the State’s proof at trial deviates from

the statutory theory of the offense as alleged in the indictment. Id. This type of variance

is always material and renders the evidence legally insufficient to support the conviction.

Boyett v. State Page 4 Id. The second way—called a non-statutory variance—occurs when the State’s proof

deviates from a “‘non-statutory allegation that is descriptive of the offense in some way.’”

Id. at 313–14 (quoting Johnson, 364 S.W.3d at 294). A non-statutory variance can be either

material or immaterial, depending on whether it would result in a different offense than

what the State alleged in the indictment. Id. at 314.

“Chapter 62 of the Texas Code of Criminal Procedure broadly sets forth the

requirements governing sex offender registration in this state.” Herron v. State, 625

S.W.3d 144, 153 (Tex. Crim. App. 2021). Chapter 62 is comprised of numerous separate

articles establishing the various requirements with which individuals subject to its terms

must comply. Id.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Gollihar v. State
46 S.W.3d 243 (Court of Criminal Appeals of Texas, 2001)
Johnson v. State
364 S.W.3d 292 (Court of Criminal Appeals of Texas, 2012)
Young v. State
341 S.W.3d 417 (Court of Criminal Appeals of Texas, 2011)
Daugherty, Tonya Jean
387 S.W.3d 654 (Court of Criminal Appeals of Texas, 2013)
Robinson, Leo Demory
466 S.W.3d 166 (Court of Criminal Appeals of Texas, 2015)
Villa v. State
514 S.W.3d 227 (Court of Criminal Appeals of Texas, 2017)
Alfaro-Jimenez v. State
577 S.W.3d 240 (Court of Criminal Appeals of Texas, 2019)
Thomas v. State
444 S.W.3d 4 (Court of Criminal Appeals of Texas, 2014)
Ramjattansingh v. State
548 S.W.3d 540 (Court of Criminal Appeals of Texas, 2018)
Hernandez v. State
556 S.W.3d 308 (Court of Criminal Appeals of Texas, 2017)
Zuniga v. State
551 S.W.3d 729 (Court of Criminal Appeals of Texas, 2018)

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