Jason Earl Wooley v. State

CourtCourt of Appeals of Texas
DecidedOctober 22, 2009
Docket14-06-00088-CR
StatusPublished

This text of Jason Earl Wooley v. State (Jason Earl Wooley v. State) 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
Jason Earl Wooley v. State, (Tex. Ct. App. 2009).

Opinion

Affirmed and Memorandum Opinion on Remand filed October 22, 2009.

In The

Fourteenth Court of Appeals

____________

NO. 14-06-00088-CR

JASON EARL WOOLEY, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 176th District Court

Harris County, Texas

Trial Court Cause No. 997,161

M E M O R A N D U M   O P I N I O N   O N   R E M A N D


A jury found appellant, Jason Earl Wooley, guilty of murder and sentenced him to confinement for forty years in the Institutional Division of the Texas Department of Criminal Justice. This court originally affirmed appellant=s conviction, finding the evidence was legally and factually sufficient when viewed using a hypothetically correct jury charge pursuant to Malik v. State, 953 S.W.2d 234, 239-40 (Tex. Crim. App. 1997). See Wooley v. State, 223 S.W.3d 732 (Tex. App.CHouston [14th Dist.] 2007, pet. granted). The Court of Criminal Appeals reversed and remanded, holding that this court=s use of a hypothetically correct charge violated appellant=s federal due process rights by affirming the judgment on a theory not submitted to the jury. See Wooley v. State, 273 S.W.3d 260, 271-73 (Tex. Crim. App. 2008). Because we find that the evidence is sufficient to support the verdict, we affirm.

Factual and Procedural Background

An indictment charged appellant with murdering the complainant by shooting him with a firearm.[1] The State presented evidence from which a jury could rationally find that appellant participated in an “ambush” of three unarmed men after luring them into a pool hall parking lot. The attack began when appellant shot his 9‑millimeter pistol into the ground as two of the intended ambush victims approached him. The complainant waited in a car in the parking lot. Immediately afterwards, other shots were heard coming from different locations in the parking lot. Shots seemed to be coming from everywhere. Appellant fired several more shots at the two men who had initially approached him. The complainant was fatally wounded, and another victim was wounded but not killed. Appellant and another person got into a car and drove off. The man accompanying appellant was Pablo Velez, identified as one of the shooters. One 9‑millimeter shell casing matching appellant’s pistol was recovered from the scene.

The police investigation identified four potential suspects as the shooters. Only appellant and Velez were identified by witnesses at trial as shooters. Police investigators concluded that four shooters using at least three different caliber guns were involved in the attack. Because the fatal bullet was not recovered, police could not determine which caliber gun killed the complainant.

The jury was instructed that it could convict appellant as a principal or as a party to Velez=s actions in firing the fatal shot. The jury convicted appellant of murder Aas charged in the indictment.@ On appeal, appellant argued that the evidence is factually insufficient to support his conviction. We decided that the submitted charge incorrectly applied the law of parties based on the evidence in that it authorized appellant=s conviction as a party upon a finding that appellant aided only Velez in causing the complainant=s death. A hypothetically correct jury charge should have authorized appellant=s conviction as a party if the jury found that appellant aided Velez Aor another person@ in causing the complainant=s death.[2] See id. Measured against this hypothetical party’s charge, we found the evidence factually sufficient to support a finding of appellant’s guilt as a party. See Wooley, 223 S.W.3d at 737‑39. 

On petition for discretionary review, the Court of Criminal Appeals held that although Malik applies to factual sufficiency reviews, appellant=s federal due process rights were violated when we affirmed appellant=s conviction under the unsubmitted theory that he aided Aanother@ to murder the complainant. 273 S.W.3d at 271. The Court of Criminal Appeals further held that this due process violation is not subject to a harm analysis. The case was remanded so that we could determine whether the judgment may be affirmed on the facts submitted to the jury based on the charge actually submitted, that is, whether sufficient evidence supports the jury=s verdict that appellant murdered the complainant either as the principal actor or as a party to Velez=s actions.[3]

Analysis

When reviewing the legal sufficiency of evidence, we examine the evidence in the light most favorable to the verdict to determine whether any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 319 (1979); Mason v. State, 905 S.W.2d 570, 574 (Tex. Crim. App. 1995).

In a factual sufficiency review, we consider all the evidence in a neutral light and reverse if the evidence supporting the verdict is so weak that the verdict seems clearly wrong and manifestly unjust, or the supporting evidence is outweighed by the great weight and preponderance of the contrary evidence so as to render the verdict clearly wrong and manifestly unjust. See Watson v. State, 204 S.W.3d 404, 414-15 (Tex. Crim. App. 2006).

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Watson v. State
204 S.W.3d 404 (Court of Criminal Appeals of Texas, 2006)
Poindexter v. State
153 S.W.3d 402 (Court of Criminal Appeals of Texas, 2005)
Mason v. State
905 S.W.2d 570 (Court of Criminal Appeals of Texas, 1995)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Geesa v. State
820 S.W.2d 154 (Court of Criminal Appeals of Texas, 1991)
Rojas v. State
171 S.W.3d 442 (Court of Appeals of Texas, 2005)
Arnold v. State
234 S.W.3d 664 (Court of Appeals of Texas, 2007)
Sims v. State
99 S.W.3d 600 (Court of Criminal Appeals of Texas, 2003)
Johnson v. State
23 S.W.3d 1 (Court of Criminal Appeals of Texas, 2000)
Wooley v. State
273 S.W.3d 260 (Court of Criminal Appeals of Texas, 2008)
Wooley v. State
223 S.W.3d 732 (Court of Appeals of Texas, 2007)
Reyes v. State
938 S.W.2d 718 (Court of Criminal Appeals of Texas, 1996)
Losada v. State
721 S.W.2d 305 (Court of Criminal Appeals of Texas, 1986)
Wygal v. State
555 S.W.2d 465 (Court of Criminal Appeals of Texas, 1977)
Jones v. State
944 S.W.2d 642 (Court of Criminal Appeals of Texas, 1996)
Thomas v. State
915 S.W.2d 597 (Court of Appeals of Texas, 1996)

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Jason Earl Wooley v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jason-earl-wooley-v-state-texapp-2009.