Herring, Timothy

CourtCourt of Appeals of Texas
DecidedApril 2, 2015
DocketPD-0376-15
StatusPublished

This text of Herring, Timothy (Herring, Timothy) 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
Herring, Timothy, (Tex. Ct. App. 2015).

Opinion

CAUSE NO. 3 76-tS ^— ORIGINAL IN THE

COURT OF CRIMINAL APPEALS

OF TEXAS

TIMOTHY HERRING/ APPELLANT APR 02 2015 VS. Abel Acosta, Clerk THE STATE OF TEXAS, RESPONDENT

APPELLANT PETITION FOR DISCRETIONARY REVIEW

FROM THE 271ST. DISTRICT COURT OF WISE COUNTY

CAUSE NUMBER (CR16345), AND THE SECOND

DISTRICT COURT OF APPEALS IN FORT WORTH, TEXAS

CAUSE NUMBER 02-12-00546-CR. FILED IN rniiDT^^n,,,,., COURT OF CRIMINAL APPEALS APR 09 2015

Abel Acosta, Clerk

TIMOTHY. HERRING (PRO-SE) TDCJ-NO. 01822827 JOHN CONNALLY UNIT 899 FM 632 KENEDY,' TEXAS 78119 TABLE OF CONTENTS

PAGE

TABLE OF CONTENTS .v. ... : .ii

INDEX OF AUTHORITY . . .iii

STATEMENT OF PROCEDURAL HISTORY. .iv

STATEMENT REGARDING ORAL ARGUMENTS . :. „ . . 1

STATEMENT OF THE CASE .. . ........ ... 2

GROUND FOR REVIEW: .... ... .... . . .... . 2

GROUND FOR REVIEW NUMBER ONE:

DID THE COURT OF APPEALS ERR IN CONDUCTING AN INCOMPLETE FACTUAL SUFFICIENCY REVIEW WHEN THE COURT FAILED TO DISCUSS KEY EVIDENCE CONTAINED IN THE RECORD, BUT INSTEAD ONLY CONSIDERED THE LEGAL SUFFICIENCY STANDARD OF REVIEW?

REASON FOR REVIEW:

THE COURT OF APPEALS. HAS DECIDED AN IMPORTANT QUESTION OF STATE LAW THAT IS IN CONFLICT WITH APPLICABLE DECISIONS OF THE COURT OF CRIMINAL APPEALS, IN PARTICULAR SIMS V. STATE, NO. 1328-01 (TEX.CR.APP. MARCH 12,2003) AND CAIN v. STATE 958 S.W, 2d 404 (TEX.CR.APP. 1997)

ARGUMENT AND AUTHORITIES. . .... . ... 3

PRAYER FOR RELIEF. . ., . .4

CERTIFICATE OF SERVICE. . . ... ..... .-v. 5

APPENDIX [OPINION] ATTACHED

11 INDEX OF AUTHORITIES

STATE CASES: PAGES

SIMS v. STATE, NO. 1328-01 (TEX.CR.APP. MARCH 12, 2003) .2,3,4 CAIN v. STATE, 958 S.W.2d 404,408 (TEX.CR.APP.1997) 2,3-4

FEDERAL LAW

JACKSON v. VIRGINIA 443 U.S. 307, 319 (99 S Ct.2781,2789 (1979).3

STATUES

SEC. 15.01 (a), TEX.PENAL CODE ANN. (WEST 2011) iv,3 SEC. 19.02 (b)(1), TEX.PENAL CODE ANN (WEST 2011). iv,3 SEC. 19.03 (a)(1), TEX.-PENAL CODE ANN. (WEST SUPP. 2013) iv,3

CONSTITUTION PROVISIONS

14TH AMENDMENT U.S. CONST .. .. .-2,3

6TH AMENDMENT U.S. CONST - 2.3

ART. 1 SEC. 10- TEX. CONST 2,3

ill STATEMENT OF PROCEDURAL HISTORY

Appellant was indicted for Attempted Capital Murder. The

offense was alleged to have occurred on or about June 2011.

A jury convicted Appellant of Attempted Capital Murder, based

ed use of a motor vehicle (The Tractor), a State jail Felony.

The Trial Court sentenced appellant to Twenty (20) years confine

ment for the attempted capital murder conviction.

Appellant Appealed to the second District Court of Appeals

in Fort worth, Texas.

On January 16, 2014 the Fort Worth court of Appeals rendered

its decision affirming appellant's judgment of conviction. Appe

llant file a request for a out of time Petition for Discretionary

Review. On February 11, 2015, the Texas Court of Criminal Appeals

Granted the request. Appellant now files this Petition for Discr

etionary Review with the clerk of the Court of Appeals for filing

within the Thirty (30) days after the court of criminal appeals

made its Final Ruling on the cause.

IV CAUSE NO.

IN THE

TIMOTHY HERRING, APPELLANT

VS.

THE STATE OF TEXAS, RESPONDENT

APPELLANTS PETITION FOR DISCRETIONARY REVIEW

TO THE COURT OF CRIMINAL APPEALS OF TEXAS-

APPELLANT RESPECTFULLY SUBMITS THIS PETITION FOR DISCRETIONA

RY REVIEW AND MOVES THAT THIS HONORABLE COURT GRANT REVIEW OF

THIS CAUSE AND OFFERS THE FOLLOWING IN SUPPORT THEREOF:

STATEMENT REGARDING ORAL ARGUMENT

APPELLANT REQUESTS ORAL ARGUMENT IN THIS CASE BECAUSE SUCH

ARGUMENT MAY ASSIST THE COURT IN APPLYING THE FACTS TO THE TSSUES

RAISED. IT IS SUGGESTED THAT ORAL ARGUMENT MAY HELP SIMPLIFY

THE FACTS AND CLARIFY THE ISSUES. STATEMENT OF THE CASE

Appellant was convicted of Attempted Capital Murder by a

jury and sentence to Twenty (20) years of confinement by the

court. Appellant seeks review of the court of appeals judgment

affirming his conviction.

Specifically, The Court of Appeals did not detail or discuss

the evidence in its factual sufficiency review and only applied

the legal sufficiency review and did not properly evaluate the

record in relation to the, "Evidentiary Sufficiency" complaint.

GROUNDS AND REASONS FOR REVIEW

GROUND FOR REVIEW NUMBER ONE (RESTATED):

Did the court of appeals conduct an incomplete factual suffi

ciency review when the court failed to discuss key evidence

contained in the record, but instead only considered the legal

sufficiency standard of review?

REASONS FOR REVIEW

The Court of Appeals has decided an important question of

State or Federal law that is in conflict with Applicable decis

ions of the Court of Criminal Appeals, in particular, Sims v.

State, NO. 1328-01 (TEX.CR.APP. MARCH 12,2003) and CAIN v. STATE,

958 S.W.-2d, 404 (TEX .CR. APP .1997 ). ARGUMENT AND AUTHORITIES

The Court of Appeals affirmed the judgment of conviction

and held cnat the evidence was sufficient to support the issue

of whether the evidence showed the offense was committed with

the "intent'* to "kill*' Trooper Patterson.

The Court of Appeals discussed some of the evidence then

summarily held the..."Viewing the evidence in tne light most

favorable to the jury's verdict and deferring to the jury's

weighing of the evidence, we conclude that a rational factfinder

could have found the elements of attempted capital murder beyond

a reasonable doubt." See, (CR. APP. OP. PP. 15-16) Quote

JACKSON v. VIRGINIA, 443 U.S. 307, 319 (99 S.Ct. 2781, 2789

(1979). The Court did not, however refer to key evidence contain

ed in the record or separately discuss the two different standard

of review.

The following evidence, in which the court of appeals failed

to consider, consisted of: (1) The Police received a report

that two people were traveling in wise County in a white van

that was stolen (2) The Police found the van and although they

quickly arrested the passenger, the driver (Appellant) escaped

and commandeered an orange tractor that was parked in a driveway

(3) The tractor was going as fast as it would go and was moving

"away from law enforcement vehicles while attempting to evade

them." (4) The. chase had been continuing for over an hour. See,

(CR.AFP.OP.PP. 2-3). None of this evidence was discussed in

the court review.

The Court of Appeals has failed to conduct a meaningful

factual sufficiency review as specified by this courc's decision

3 in CANE v. STATE, 958 S.W. 2d 404, 408 (TEX.CR.APP. 1997)(Should

apply proper standard of review and discuss all the evidence)

The requirement to discuss evidence identified by the appellant

was reiterated by this court in SIMS v. STATE NO. 1328-01 (TEX.

CR.APP. March 12, 2003).

Like the court of appeals in SIMS SUPRA, the reviewing court

in this case never mentioned, or presumably considered the evid

ence contained in the record. Id. at 3. The SIMS Opinion reversed

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