Kenneth Foster v. the State of Texas

CourtCourt of Appeals of Texas
DecidedSeptember 4, 2025
Docket06-24-00214-CR
StatusPublished

This text of Kenneth Foster v. the State of Texas (Kenneth Foster 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
Kenneth Foster v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

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

No. 06-24-00214-CR

KENNETH FOSTER, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 202nd District Court Bowie County, Texas Trial Court No. 23F-1220-202

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

A Bowie County jury convicted Kenneth Foster of capital murder and sentenced him to

life without parole. See TEX. PENAL CODE ANN. § 19.03 (Supp.).

Foster claims the evidence was legally insufficient to support his conviction because “no

rational juror could find beyond a reasonable doubt that the State disproved [his] deadly force

self-defense and necessity theories.” Because we conclude there was sufficient evidence to

support the jury’s rejection of Foster’s defensive theories, we affirm the trial court’s judgment.

I. Applicable Law and Standard of Review

A. Capital Murder

A person commits the offense of capital murder if the person, “while incarcerated” for

capital murder, TEX. PENAL CODE ANN. § 19.03(a)(6)(A), “intentionally or knowingly causes the

death of an individual.” TEX. PENAL CODE ANN. § 19.02(b)(1) (Supp.).

B. Justification Defenses

Relevant to Foster’s claims, the Texas Penal Code provides for defenses to prosecution

when “the conduct in question is justified” under the theories of necessity or self-defense using

deadly force. TEX. PENAL CODE ANN. § 9.02; see TEX. PENAL CODE ANN. §§ 9.22, 9.31.

A defendant’s “[c]onduct is justified” due to necessity if “the actor reasonably believes

the conduct is immediately necessary to avoid imminent harm” and “the desirability and urgency

of avoiding the harm clearly outweigh, according to ordinary standards of reasonableness, the

harm sought to be prevented by the law proscribing the conduct.” TEX. PENAL CODE ANN.

§ 9.22(1)–(2). “[A] necessity defense requires there to be, among other proof, evidence of a

2 specific imminent harm on the occasion in question.”1 Daugherty v. State, No. 06-18-00167-CR,

2019 WL 2195256, at *1 (Tex. App.—Texarkana 2019, pet. ref’d) (mem. op., not designated for

publication) (citing Kelso v. State, 562 S.W.3d 120, 132–33 (Tex. App.—Texarkana 2018, pet.

ref’d)).

“‘Imminent’ means something that is immediate, something that is going to happen

now.” Kelso v. State, 562 S.W.3d 120, 132 (Tex. App.—Texarkana 2018, pet. ref’d) (quoting

Murkledove v. State, 437 S.W.3d 17, 25 (Tex. App.—Fort Worth 2014, pet. dism’d, untimely

filed)). “Harm is imminent when there is an emergency situation and it is ‘immediately

necessary’ to avoid that harm, in other words, when a ‘split-second decision’ is required without

time to consider the law.” Id. (quoting Murkledove, 427 S.W.3d at 25). “Imminence ‘has two

components: (1) the person making the threat must intend and be prepared to carry out the threat

immediately, and (2) the threat must be predicated on the threatened person’s failure to commit

the charged offense immediately.’” Id. (quoting Cormier v. State, 540 S.W.3d 185, 190 (Tex.

App.—Houston [1st Dist.] 2017, pet. ref’d)). “Imminent harm must be shown by affirmative

1 We have previously stated that another element of properly raising a confession-and-avoidance defense, particularly necessity, required admitting to commission of the charged offense. Daugherty, 2019 WL 2195256, at *1 (quoting Arnwine v. State, 20 S.W.3d 155, 158 (Tex. App.—Texarkana 2000, no pet.) (citing Juarez v. State, 308 S.W.3d 398, 399 (Tex. Crim. App. 2010); Dearborn v. State, 420 S.W.3d 366, 375 (Tex. App.—Houston [14th Dist.] 2014, no pet.))). “However, that formulation has been rephrased and even seemingly undermined.” Rodriguez v. State, 629 S.W.3d 229, 231–32 (Tex. Crim. App. 2021) (citing Juarez, 308 S.W.3d at 401–02 and comparing Juarez with Gamino v. State, 537 S.W.3d 507, 512 (Tex. Crim. App. 2017)). “Admitting to the conduct does not necessarily mean admitting to every element of the offense. For example, a defendant can ‘sufficiently admit to the commission of the offense’ of murder even when denying an intent to kill.” Gamino, 537 S.W.3d at 512 (quoting Martinez v. State, 775 S.W.2d 645, 647 (Tex. Crim. App. 1989)). Because neither Foster nor the State discussed whether Foster’s admission of the offense, or lack thereof, precluded his defenses of necessity and self- defense, we do not address this matter further.

3 evidence.” Id. “A threat of harm at some indefinite time in the future is insufficient to satisfy

the requirement of imminence.” Id.

Regarding the justification of self-defense, “Penal Code Section 9.31 provides that,

subject to certain exceptions, a person is justified in using force against another ‘when and to the

degree the actor reasonably believes the force is immediately necessary to protect the actor

against the other’s use or attempted use of unlawful force.’” Braughton v. State, 569 S.W.3d

596, 606 (Tex. Crim. App. 2018) (quoting TEX. PENAL CODE ANN. § 9.31(a)). “The use of force

is not justified in response to verbal provocation alone, or if the actor provoked the other’s use or

attempted use of unlawful force.” Id. (citing TEX. PENAL CODE ANN. § 9.31(b)). And with

respect to deadly force, “[a] person is justified in using deadly force against another (1) if he

would be justified in using force against the other under section 9.31, and (2) ‘when and to the

degree the actor reasonably believes the deadly force is immediately necessary: (A) to protect

the actor against the other’s use or attempted use of unlawful deadly force . . . .’” Id. at 606–07

(quoting TEX. PENAL CODE ANN. § 9.32(a)). “A ‘reasonable belief’ in this context is defined as

‘one that would be held by an ordinary and prudent man in the same circumstances as the

actor.’” Id. at 606 (quoting TEX. PENAL CODE ANN. § 1.07(a)(42)).

C. Legal Sufficiency of the Evidence

“The due process guarantee of the Fourteenth Amendment requires that a conviction be

supported by legally sufficient evidence.” Id. at 607. “We assess legal sufficiency by viewing

the evidence in the light most favorable to the verdict and asking whether any rational trier of

fact could have found the essential elements of the crime beyond a reasonable doubt.” Bittick v.

4 State, 707 S.W.3d 366, 368 (Tex. Crim. App. 2024) (citing Jackson v. Virginia, 443 U.S. 307,

319 (1979)). “We compare the trial evidence to ‘the elements of the offense as defined by a

hypothetically correct jury charge for the case.’” Id. at 369 (quoting Zuniga v. State, 551 S.W.3d

729, 733 (Tex. Crim. App. 2018)).

“This familiar standard ‘recognizes the trier of fact’s role as the sole judge of the weight

and credibility of the evidence after drawing reasonable inferences from the evidence.’”

Braughton, 569 S.W.3d at 608 (quoting Adames v.

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