Marcel Reyes v. the State of Texas

CourtTexas Court of Appeals, 4th District (San Antonio)
DecidedJune 3, 2026
Docket04-25-00522-CR
StatusPublished

This text of Marcel Reyes v. the State of Texas (Marcel Reyes v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 4th District (San Antonio) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marcel Reyes v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-25-00522-CR

Marcel REYES, Appellant

v.

The STATE of Texas, Appellee

From the 226th Judicial District Court, Bexar County, Texas Trial Court No. 2024-CR-008324 Honorable Benjamin Robertson, Judge Presiding

Opinion by: Lori Massey Brissette, Justice

Sitting: Rebeca C. Martinez, Chief Justice Lori Massey Brissette, Justice Velia J. Meza, Justice

Delivered and Filed: June 3, 2026

AFFIRMED

Appellant Marcel Reyes appeals his judgment of conviction for retaliation pursuant to

Texas Penal Code § 36.06. He contends the evidence presented at trial was legally insufficient for

the jury to find him guilty of the offense because no harmful act was alleged. Based on the law

and the record, we affirm. 04-25-00522-CR

BACKGROUND

Reyes was indicted for retaliation in connection with a voicemail and text messages he sent

his parole officer containing veiled threats. TEX. PENAL CODE § 36.06. After a one-day trial, a jury

found him guilty, and the trial court sentenced him to eight years with the Texas Department of

Criminal Justice Institutional Division. This appeal followed.

LEGAL SUFFICIENCY

A. Facts

Vanessa Hyland, a former State of Texas parole officer, testified Reyes was assigned to

her on May 8, 2025, and she conducted a home visit on him the following day. During the home

visit, Reyes had a lot of questions about his term of supervision, and she told him they could

discuss it in the parole office at a later time. Reyes—who testified he was very anxious about the

home visit—asked Hyland for her help in connection with a purported twenty-day miscalculation

of his discharge date and for mental health services, but she told him it was not her job to help

him. He was very upset about the interaction.

A few days later, on Sunday, May 12, 2024 Reyes sent Hyland multiple text messages

including:

• “I can very easily be provoked to get violent. Especially now.” • “Don’t waste your time and effort on a violation report much less a . . . warrant. The new cautions would not give [me] prison time or [make me] eligible for any program. You would just piss me off. And I would be a civilian. And a misdemeanor would be worth it.” • “YOU TRIPPED AND FELL DOWN THE STAIRS TO THE STREET.” 1 • “When I was very little, I was a very mean boy. I even beat people up at Bible class. Even beat little girls I liked. Even invite[d] neighbors to play basketball and kick[ed] them out. I can show you bully just to have fun.” • “I[n] fact . . . [my] faint presence at your residence would not let you sleep in comfort.”

1 Hyland testified she never actually tripped and fell down the stairs.

-2- 04-25-00522-CR

• RESPECT MY HOUSE, I DON’T CARE IF YOU ARE ON OFFICIAL CAPACITY, THERE WILL BE PHYSICAL CONTACT ALL THE WAY TO THE STREET. THIS IS ROUTINE WITH CRAZY WOMEN. AND ALL THE AFFIDAVITS WILL BE PREPARED EXACTLY THE SAME.

Reyes also left her a voicemail, during which he apologized for seeming “rude, threatening, or

harassing,” explaining “in a stressful environment I become ballistic and once I realize people are

taking advantage of me, I eventually snap.” Hyland testified she understood the messages to be

Reyes threatening to assault her because she was his parole officer and he wanted a new one. She

believed Reyes intended for her to know that if she did not do what he wanted, he would get violent

with her.

Reyes testified he was not upset when he sent the text messages; he was “stressed out” and

“venting.” He testified he could not “control [his] voice.” He further testified he did not intend to

hurt Hyland and would have never acted on his threats. He further testified he sent the messages

because he had wanted to go to a mental health services clinic, instead of meeting with her, and

also wanted a different parole officer.

B. Analysis

Reyes contends his text messages were legally insufficient for the jury to find him guilty

because they did not contain what could be interpreted by a reasonable parole officer as threats of

specific harm or that he intended to threaten harm. As such, the messages comprised little more

than a mere modicum of evidence and were legally insufficient under Jackson v. Virginia. See

generally 443 U.S. 307 (1979).

1. Standard of Review and Applicable Law

Evidence is legally sufficient to support a conviction if, viewing all of the evidence in the

light most favorable to the verdict, any rational juror could have found the essential elements of

the crime beyond a reasonable doubt. See, e.g., Hernandez v. State, 727 S.W.3d 83, 87 (Tex. Crim.

-3- 04-25-00522-CR

App. 2025). In our review, we consider all the evidence admitted at trial. See id. But this court

does not act as a “thirteenth juror,” and we do not substitute our judgment for that of the factfinder

by reevaluating the weight and credibility of the evidence. Id. The jury may draw reasonable

inferences from the evidence admitted at trial based on their own common sense, personal

experience, and “observations from life.” See id. We measure the sufficiency of the evidence

against the hypothetically correct jury charge. Id. A hypothetically correct jury charge accurately

sets forth the statutory elements as modified by the charging instrument, does not increase the

burden of proof of the State, and adequately describes the charged offense. Id.

A person commits the third-degree felony offense of retaliation if the person intentionally

or knowingly threatens to harm another by an unlawful act in retaliation for or on account of the

service or status of another as a public servant. TEX. PEN. CODE § 36.06(a)(1)(A). 2 Retaliatory

intent may be inferred from an accused’s acts, words, or conduct. Brock, 495 S.W.3d at 16. The

statute does not require the threatened retaliatory harm be imminent, that the actor actually intend

to carry out his threat, or that the actor take any affirmative steps to carry out the threat. Id.

Comments may be evaluated as threats based, not just on the language used, but also the context

within which they are uttered. Id. at 17. We apply an objective standard to determine whether a

particular statement is properly considered a threat: whether a reasonable person would believe the

recipient of the statement would believe it was a serious expression of intent to harm. See id. at 17

(“The test is whether a threat would justify apprehension by an ordinary hearer, not whether the

threat communicated over the telephone caused a particular recipient to actually become

apprehensive.” (quoting Manemann v. State, 878 S.W.2d 334, 337 (Tex. App.—Austin 1994, pet.

2 Because retaliation is a result-oriented offense, we focus on whether the threat is done with an intent to effect the retaliation for or on account of the service or status of another as a public servant. Brock v. State, 495 S.W.3d 1, 16 (Tex. App.—Waco 2016, pet. ref’d).

-4- 04-25-00522-CR

ref’d)). The maker of the statement does not need to directly express a threat of physical harm.

Brock, 495 S.W.3d at 17. The threat of physical harm, viewed under consideration of all

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)
Cada v. State
334 S.W.3d 766 (Court of Criminal Appeals of Texas, 2011)
Manemann v. State
878 S.W.2d 334 (Court of Appeals of Texas, 1994)
Brock v. State
495 S.W.3d 1 (Court of Appeals of Texas, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Marcel Reyes v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marcel-reyes-v-the-state-of-texas-txctapp4-2026.