James Christopher Stewart v. the State of Texas

CourtCourt of Appeals of Texas
DecidedNovember 22, 2024
Docket08-23-00290-CR
StatusPublished

This text of James Christopher Stewart v. the State of Texas (James Christopher Stewart 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
James Christopher Stewart v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS

JAMES CHRISTOPHER STEWART, § No. 08-23-00290-CR

Appellant, § Appeal from the

v. § 399th Judicial District Court

THE STATE OF TEXAS, § of Bexar County, Texas

Appellee. § (TC# 2020CR6504)

MEMORANDUM OPINION1

At trial, there was no dispute that Appellant, James Christopher Stewart, shot and killed

his girlfriend, Tiffany Washington, while the couple was inside their house. In two counts,

Appellant was charged with the offense of murder and the offense of aggravated assault with a

deadly weapon causing serious bodily injury to a person with whom he had a dating relationship,

alleged to have been committed on or about April 25, 2020. Appellant argued to the jury that he

shot Ms. Washington accidently. The jury found him guilty on both counts and assessed

punishment at 75 years’ confinement with no fine. The trial court entered a judgment of conviction

on the murder charge, with punishment at 75 years’ confinement and no fine.

1 The appeal was transferred to this Court from the Fourth Court of Appeals pursuant to a Texas Supreme Court docket equalization order. Accordingly, we apply the Fourth Court of Appeals’ precedent to the extent it conflicts with our own. See Tex. R. App. P. 41.3. In a single issue on appeal, Appellant asserts the evidence is legally insufficient to support

his conviction. According to Appellant, the testimony of two Bexar County Sheriff’s Department

investigators (Frank Spencer Stubbs, III and Houston Pons) about what Appellant said during a

video-recorded interview was irrelevant, mere speculation, and personal opinion.2 And, he argues,

absent their speculative, inconsistent, and opinion testimony, the evidence at trial was legally

insufficient to prove he intentionally or knowingly caused Ms. Washington’s death. We conclude

the evidence is legally sufficient; therefore, we affirm.

I. STANDARD OF REVIEW AND APPLICABLE LAW Under the Due Process Clause of the U.S. Constitution, the State is required to prove every

element of the charged offense beyond a reasonable doubt. See Jackson v. Virginia, 443 U.S. 307,

318–19 (1979). In assessing the legal sufficiency of the evidence to support a criminal conviction,

“we consider all the evidence in the light most favorable to the verdict and determine whether,

based on that evidence and reasonable inferences therefrom, a rational juror could have found the

essential elements of the crime beyond a reasonable doubt.” Hooper v. State, 214 S.W.3d 9, 13

(Tex. Crim. App. 2007). We defer to the trier of fact to resolve conflicts in testimony, weigh the

evidence, and draw reasonable inferences from basic facts to ultimate facts. Id. “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.’” Id. (quoting Cordova v. State, 698 S.W.2d 107, 111

(Tex. Crim. App. 1985) (en banc)). “Each fact need not point directly and independently to the

2 At trial, defense counsel raised various objections to the testimony of Investigators Stubbs and Pons, including narrative, speculative, leading, asked-and-answered, and reading from a report. Some of the objections were sustained and others were overruled. On appeal, Appellant does not assert the trial court abused its discretion regarding its evidentiary rulings or by allowing the testimony in evidence.

2 guilt of the appellant, as long as the cumulative force of all the incriminating circumstances is

sufficient to support the conviction.” Id. “Circumstantial evidence is as probative as direct

evidence in establishing the guilt of an actor, and circumstantial evidence alone can be sufficient

to establish guilt.” Id.

In applying the legal sufficiency test, we defer to the fact-finder in terms of weighing

inconsistencies in and assessing the credibility of witness testimony in deciding whether to believe

the testimony. Brooks v. State, 323 S.W.3d 893, 899 (Tex. Crim. App. 2010). A jury is entitled to

accept or reject any or all of the testimony of any witness. Adelman v. State, 828 S.W.2d 418, 421

(Tex. Crim. App. 1992) (en banc). We may not reevaluate the weight and credibility of the

evidence to substitute our judgment for that of the fact-finder. Dewberry v. State, 4 S.W.3d 735,

740 (Tex. Crim. App. 1999).

A person commits the offense of murder “if the person . . . (1) intentionally or knowingly

causes the death of an individual [or] (2) intends to cause serious bodily injury and commits an act

clearly dangerous to human life that causes the death of an individual[.]” Tex. Penal Code Ann.

§ 19.02(b)(1–2). “Except as provided by Subsection (d), an offense under this section is a felony

of the first degree.” Id. § 19.02(c). Subsection (d) provides that, during the punishment phase, a

defendant may raise the issue of whether he caused the death under the immediate influence of

sudden passion arising from an adequate cause. Id. § 19.02(d). If the defendant proves the issue in

the affirmative by a preponderance of the evidence, the offense is a second-degree felony. Id.

We take Appellant’s contention that Ms. Washington’s death was an accident as a

challenge to the mens rea required for his murder conviction. In general, to establish that a

defendant committed an offense, the State must establish the defendant had the mental state

required for the particular offense with which he is charged. See Ramirez-Memije v. State, 444

3 S.W.3d 624, 627 (Tex. Crim. App. 2014); Marquez v. State, 697 S.W.3d 485, 498 (Tex. App.—

El Paso 2024, no pet.).

As relevant here, the State was required to prove the element of intent. See Tex. Penal Code

Ann. § 19.02(b)(1–2). “A person acts intentionally, or with intent, with respect to the nature of his

conduct or to a result of his conduct when it is his conscious objective or desire to engage in the

conduct or cause the result.” Tex. Penal Code Ann. § 6.03(a); see Schroeder v. State, 123 S.W.3d

398, 400 (Tex. Crim. App. 2003) (en banc) (“[m]urder is a ‘result of conduct’ offense, which

means that the culpable mental state relates to the result of the conduct, i.e., the causing of the

death”). Under Penal Code § 19.02(b)(1), the mens rea element requires that the defendant must

have intentionally or knowingly caused the death of the victim. See Smith v. State, 554 S.W.3d 23,

25 (Tex. Crim. App. 2018). Thus, a conviction under § 19.02(b)(1) requires an intent to cause

death. See Walter v. State, 581 S.W.3d 957, 970 (Tex. App.—Eastland 2019, pet. ref’d).

Appellant’s contention that Ms. Washington’s death was an accident would be relevant to a

conviction under § 19.02(b)(1) to the extent that it was an unintended result. See id. Under

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

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Laster v. State
275 S.W.3d 512 (Court of Criminal Appeals of Texas, 2009)
Schroeder v. State
123 S.W.3d 398 (Court of Criminal Appeals of Texas, 2003)
Reyes v. State
3 S.W.3d 623 (Court of Appeals of Texas, 1999)
Adelman v. State
828 S.W.2d 418 (Court of Criminal Appeals of Texas, 1992)
Cordova v. State
698 S.W.2d 107 (Court of Criminal Appeals of Texas, 1985)
Brown v. State
122 S.W.3d 794 (Court of Criminal Appeals of Texas, 2003)
Dewberry v. State
4 S.W.3d 735 (Court of Criminal Appeals of Texas, 1999)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Manrique v. State
994 S.W.2d 640 (Court of Criminal Appeals of Texas, 1999)
Cavazos, Abraham
382 S.W.3d 377 (Court of Criminal Appeals of Texas, 2012)
Nisbett, Rex Allen
552 S.W.3d 244 (Court of Criminal Appeals of Texas, 2018)
Smith v. State
554 S.W.3d 23 (Court of Criminal Appeals of Texas, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
James Christopher Stewart v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-christopher-stewart-v-the-state-of-texas-texapp-2024.