Houston Samuel Hammons v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJuly 17, 2025
Docket06-24-00217-CR
StatusPublished

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Bluebook
Houston Samuel Hammons v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In the Court of Appeals Sixth Appellate District of Texas at Texarkana

No. 06-24-00217-CR

HOUSTON SAMUEL HAMMONS, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 336th District Court Fannin County, Texas Trial Court No. CR-24-46712

Before Stevens, C.J., van Cleef and Rambin, JJ. Memorandum Opinion by Chief Justice Stevens MEMORANDUM OPINION

A Fannin County jury convicted Houston Samuel Hammons of criminal mischief causing

pecuniary loss of $2,500.00 or more but less than $30,000.00, a state jail felony. See TEX. PENAL

CODE ANN. § 28.03(b)(4) (Supp.). For this offense, the jury assessed a punishment of two years’

imprisonment, and the trial court ordered Hammons to pay $4,044.00 in restitution to his victims.

In his sole issue on appeal, Hammons argues that the evidence is legally insufficient to support

the element of pecuniary loss.1 Because we find that legally sufficient evidence supported the

amount of pecuniary loss, we affirm the trial court’s judgment.

I. Standard of Review

“In evaluating legal sufficiency, we review all the evidence in the light most favorable to

the trial court’s judgment to determine whether any rational jury could have found the essential

elements of the offense beyond a reasonable doubt.” Williamson v. State, 589 S.W.3d 292, 297

(Tex. App.—Texarkana 2019, pet. ref’d) (citing Brooks v. State, 323 S.W.3d 893, 912 (Tex.

Crim. App. 2010) (plurality op.); Jackson v. Virginia, 443 U.S. 307, 319 (1979); Hartsfield v.

State, 305 S.W.3d 859, 863 (Tex. App.—Texarkana 2010, pet. ref’d)). “Our rigorous [legal

sufficiency] review focuses on the quality of the evidence presented.” Id. (citing Brooks, 323

S.W.3d at 917–18 (Cochran, J., concurring)). “We examine legal sufficiency under the direction

of the Brooks opinion, while giving deference to the responsibility of the jury ‘to fairly resolve

conflicts in testimony, to weigh the evidence, and to draw reasonable inferences from basic facts

to ultimate facts.’” Id. (quoting Hooper v. State, 214 S.W.3d 9, 13 (Tex. Crim. App. 2007)

1 In our cause number 06-24-00216-CR, Hammons appeals his conviction for family violence assault by occlusion. 2 (citing Jackson, 443 U.S. at 318–19; Clayton v. State, 235 S.W.3d 772, 778 (Tex. Crim. App.

2007))).

“Legal sufficiency of the evidence is measured by the elements of the offense as defined

by a hypothetically correct jury charge.” Id. at 298 (citing 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. (quoting Malik, 953 S.W.2d at 240).

Here, the State alleged that Hammons, “pursuant to one scheme or continuing course of

conduct,” intentionally or knowingly damaged or destroyed “the door of a Trenton [Police

Department (TPD)] squad car and a car window, by hitting[,] striking, elbowing, and/or kicking

it, without the effective consent of Trenton Police or Kayla McBride, the owner[s] of the

property, and thereby caused . . . the aggregate amount of pecuniary loss” “of $2,500[.00] or

more but less than $30,000[.00] to the owner[s].”

II. The Evidence at Trial

At trial, McBride testified that she was at a gas station when Hammons hit her passenger

side window with “the side of his arm or his elbow,” shattering it. The State introduced photos

of the broken car window for the jury to see. A gas station employee called the TPD.

Officer Ken Franklin, with the TPD, arrived at the scene, arrested Hammons, and placed

him in his Chevrolet Tahoe patrol unit. Franklin testified that, as he was transporting Hammons,

Hammons began “kicking [the] car door with his feet.” Hammons’s conduct was captured by the

3 backseat camera in Franklin’s patrol unit, and the State played the footage for the jury. After

Hammons also kicked the patrol unit’s window, Franklin stopped the patrol unit to try to calm

Hammons down. Franklin photographed the “damage to [the] rear passenger door” of his patrol

unit showing that Hammons “bent the frame approximately one inch out.” As a result, the door

could not be properly shut because a gap existed. Franklin testified that he had inspected the

patrol unit at the beginning of his shift and noted no damage on the vehicle.

McBride testified that her car window was replaced by Unique Crystal Auto Glass and

that the repair cost $175.00. The State introduced the receipt from the repair shop, which

showed that the repair cost of $175.00 was actually paid.

Franklin testified that he took his patrol unit to a body shop called Collision 1st a few

days after the incident and asked them for an estimate for the repairs. The estimate from

Collison 1st, which contained an itemized list of parts requiring repair, and cost to repair each

item, totaled $3,869.92. In support of the estimate, the State presented Gregory Taft, an

employee of Collision 1st, as an expert witness.2 Taft testified that he had provided Franklin

with the estimate for the cost of repairing the damage caused to the Tahoe. Taft said that he had

been working at Collision 1st for ten years and, for the past four years, had been “estimating and

managing.” Taft, who described each damaged part of the patrol unit in detail, testified that the

$3,869.92 estimate was for “everything that would [be] require[d] to get that door back to the

original condition” “prior to being bent” and was a “common” cost “for that kind of vehicle and

that kind of repair.”

2 Hammons does not challenge Taft’s qualifications on appeal. 4 III. Legally Sufficient Evidence Supported the Amount of Pecuniary Loss

A person commits criminal mischief if he, “without the effective consent of the owner[s]

. . . intentionally or knowingly damages or destroys the tangible property of the owner[s].” TEX.

PENAL CODE ANN. § 28.03 (Supp.). On appeal, Hammons does not argue that the State failed to

prove that he intentionally or knowingly damaged McBride’s and TPD’s property without their

consent. Instead, he only argues that the evidence is insufficient to support the amount of

pecuniary loss.

Because the pecuniary loss resulting from the criminal mischief determines the grade of

the offense, the value of pecuniary loss is a critical element of the offense. See TEX. PENAL

CODE ANN. § 28.03(b); Campbell v. State, 426 S.W.3d 780, 784 (Tex. Crim. App. 2014);

Elomary v. State, 796 S.W.2d 191, 192–93 (Tex. Crim. App. 1990). Since the record here

establishes that the vehicles were damaged, not destroyed, the pecuniary loss is determined by

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Barnes v. State
248 S.W.3d 217 (Court of Appeals of Texas, 2007)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Clayton v. State
235 S.W.3d 772 (Court of Criminal Appeals of Texas, 2007)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
English v. State
171 S.W.3d 625 (Court of Appeals of Texas, 2005)
Kinkade v. State
787 S.W.2d 507 (Court of Appeals of Texas, 1990)
Hartsfield v. State
305 S.W.3d 859 (Court of Appeals of Texas, 2010)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Holz v. State
320 S.W.3d 344 (Court of Criminal Appeals of Texas, 2010)
Espinoza v. State
955 S.W.2d 108 (Court of Appeals of Texas, 1997)
Elomary v. State
796 S.W.2d 191 (Court of Criminal Appeals of Texas, 1990)
Campbell v. State
426 S.W.3d 780 (Court of Criminal Appeals of Texas, 2014)

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