Hudson, William Mitchell

CourtCourt of Criminal Appeals of Texas
DecidedApril 14, 2021
DocketAP-77,077
StatusPublished

This text of Hudson, William Mitchell (Hudson, William Mitchell) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hudson, William Mitchell, (Tex. 2021).

Opinion

IN THE COURT OF CRIMINAL APPEALS OF TEXAS NO. AP-77,077

WILLIAM MITCHELL HUDSON, Appellant

v.

THE STATE OF TEXAS

ON DIRECT APPEAL FROM CAUSE NO. 3CR-16-32585 IN THE 3RD JUDICIAL DISTRICT COURT ANDERSON COUNTY

WALKER, J., delivered the opinion for a unanimous Court.

OPINION

In November 2017, a jury convicted Appellant of capital murder for murdering Carl and

Hannah Johnson in the same criminal transaction. See TEX. PENAL CODE § 19.03(a)(7). Pursuant to

the jury’s answers to the special issues set forth in Texas Code of Criminal Procedure Article 37.071,

§§ 2(b) and 2(e), the trial judge sentenced Appellant to death. TEX. CODE CRIM. PROC. art. 37.071, 2

§ 2(g).1 Direct appeal to this Court is automatic. Art. 37.071, § 2(h). Appellant raises two points of

error. After reviewing Appellant’s points of error, we find them to be without merit. Consequently,

we affirm the trial court’s judgment and sentence of death.

I — Background

On Saturday, November 14, 2015, Tom Kamp; his adults sons, Nathan and Austin; Tom’s

girlfriend, Hannah Johnson; her six-year-old son, K.J.; and her parents, Carl and Cindy Johnson,

arrived to camp on land Tom had bought in Anderson County. Tragically for the group, Appellant

wanted and believed himself entitled to this same land. The property had been in Appellant’s family

for generations, but he was unable to buy it when it had been offered for sale.

Carl and Cindy arrived first at the property, towing an Airstream trailer. There was an

unauthorized padlock on the gate. Using bolt cutters Tom had provided, they removed the padlock

and entered the property. When their truck and the Airstream subsequently became stuck in the mud,

Carl and Cindy had a loud argument. A man later identified as Appellant drove up to them; he was

angry about the noise but then insisted that he would help them. Appellant, who lived on the adjacent

property, left and returned shortly on a tractor. At about 4:30 p.m., while Appellant was freeing the

truck and Airstream, Hannah, Nathan, Austin, and K.J. arrived in Tom’s truck, towing a trailer with

an ATV.

The group tried to pay Appellant for his help, but he refused money and said he would like

to have a beer with them instead. As the group talked and Appellant learned that Carl and Cindy had

cut the padlock off the gate, he became upset, calling the act “disrespectful.” Appellant told them

1 Unless otherwise indicated, all future references to Articles refer to the Code of Criminal Procedure. 3

that he had wanted to buy the land. Cindy and Carl apologized to Appellant for cutting the padlock,

even though they did not think they needed to. Carl also tried to pacify Appellant by telling him that

they were now friends and continuing to make conversation with him.

The family was sitting around the campfire when Tom arrived at about 8:00 p.m. in Hannah’s

car. Appellant was still with them. Later, although Hannah privately expressed a desire for Appellant

to leave, Tom, Nathan, Austin, K.J., and Appellant got in the ATV together to collect more firewood.

Cindy, Carl, and Hannah stayed behind to make dinner.

Cindy, Carl, and Hannah later heard gunshots but they thought it was just people “fooling

around.” Appellant eventually returned alone in the ATV and began talking to Carl. Meanwhile,

Hannah saw something that alarmed her. She ran to Tom’s truck, yelling for her father and pointing

at the back of the ATV. Appellant then exited the ATV and began shooting at them.

Cindy survived the attack by hiding, but Appellant killed both Carl and Hannah. Hannah’s

body was discovered nude from the waist down. Although a sexual assault examination did not

detect Appellant’s DNA inside Hannah’s body, DNA consistent with hers was detected on the crotch

of Appellant’s boxer shorts. A law enforcement dive team subsequently recovered Tom’s, Nathan’s,

Austin’s and K.J.’s bodies from a stock pond behind Appellant’s residence. The medical examiner

who conducted the six victims’ autopsies testified that they died from injuries that included gunshot

wounds and extreme blunt force trauma.

II — Challenges for Cause

In points of error one and two, Appellant alleges that the trial court erred in denying his

challenges for cause to veniremembers Brunson and Tountas. We first consider whether Appellant

has shown that any such error could have harmed him. See Comeaux v. State, 445 S.W.3d 745, 747 4

(Tex. Crim. App. 2014) (“The issue . . . is one of harm, not preservation.”); Johnson v. State, 43

S.W.3d 1, 5 n.6 (Tex. Crim. App. 2001) (stating that “[i]n the past we have confused preservation

of error and harm issues within the context of an erroneous denial of a challenge for cause”, and

noting that the steps that courts have sometimes called necessary for preservation are really to show

harm).

II(A) — Potential Harm

“[H]arm from the erroneous denial of a defense challenge for cause focuses on whether a

peremptory challenge was wrongfully taken from the defendant.” Newbury v. State, 135 S.W.3d 22,

30–31 (Tex. Crim. App. 2004) (internal quotation marks and alterations omitted). Therefore, in

addition to demonstrating error by the trial court, the appellant must show on the record that he

complied with five steps:

The first step requires the defendant to establish that he made a “clear and specific challenge for cause” against a panel member. This ensures that the defendant alerts the trial judge to the complaint at a time and in a manner in which it could be addressed. Then, the defendant must use a peremptory challenge on the complained-of member and exhaust all remaining peremptory challenges. If the defendant does not exhaust his peremptory strikes, then the trial judge’s erroneous denial has not harmed the defendant because he was not stripped of the right to dismiss an “obnoxious” juror. The defendant must then ask for an additional strike so that the judge is given the opportunity to correct his error by granting an additional peremptory strike to make up for the one that was wrongly denied. Finally, the defendant must identify on the record the objectionable juror whom he would have removed with the additional strike, but he is not required to explain why that juror is objectionable.

Comeaux, 445 S.W.3d at 750 (internal footnotes omitted). We have explained that these steps “are

intended to allow the trial judge every opportunity to correct error and to allow the defendant to

demonstrate that he did not have the benefit of using his peremptory challenges in the way that he

desired.” Id. 5

Here, the record shows that Appellant made timely and specific challenges for cause to

veniremembers Brunson and Tountas and the trial court denied those challenges. Individual

questioning of the venire ultimately yielded forty-seven veniremembers whom the trial court deemed

qualified to serve as jurors in a capital case. The parties then made their statutory peremptory

challenges. See Art. 35.15(a) (allotting the parties in a capital case fifteen peremptory challenges

each).

Appellant used his fourth and twelfth peremptory challenges to remove Brunson and Tountas

from jury service. After the parties accepted the ninth juror, Appellant used his last remaining

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Johnson v. State
43 S.W.3d 1 (Court of Criminal Appeals of Texas, 2001)
Newbury v. State
135 S.W.3d 22 (Court of Criminal Appeals of Texas, 2004)
Feldman v. State
71 S.W.3d 738 (Court of Criminal Appeals of Texas, 2002)
Gardner v. State
306 S.W.3d 274 (Court of Criminal Appeals of Texas, 2009)
Davis v. State
329 S.W.3d 798 (Court of Criminal Appeals of Texas, 2010)
Chambers v. State
866 S.W.2d 9 (Court of Criminal Appeals of Texas, 1993)
Burks v. State
876 S.W.2d 877 (Court of Criminal Appeals of Texas, 1994)
Comeaux, Farrain Joseph
445 S.W.3d 745 (Court of Criminal Appeals of Texas, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Hudson, William Mitchell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hudson-william-mitchell-texcrimapp-2021.