Mark Rios v. State

CourtCourt of Appeals of Texas
DecidedOctober 6, 2005
Docket13-04-00278-CR
StatusPublished

This text of Mark Rios v. State (Mark Rios 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
Mark Rios v. State, (Tex. Ct. App. 2005).

Opinion

                              NUMBER 13-04-278-CR

                         COURT OF APPEALS

                     THIRTEENTH DISTRICT OF TEXAS

                         CORPUS CHRISTI - EDINBURG 

MARK RIOS,                                                                                    Appellant,

v.

THE STATE OF TEXAS,                                                                 Appellee.

On appeal from the 36th District Court of San Patricio County, Texas.

                                MEMORANDUM OPINION

           Before Chief Justice Valdez and Justices Castillo and Garza

                            Memorandum Opinion by Justice Garza


Angel Medina was shot and killed in a drive-by shooting on August 6, 2003.  Appellant, Mark Rios, was indicted for Medina=s murder, along with four other co-defendants, Judas Tamayo Leal, Christopher Gutierrez, Adrian Mendoza, and Billy Joe Martinez.  Appellant, Leal, and Gutierrez were tried jointly, and the jury found them guilty of murder.  Appellant now challenges the legal and factual sufficiency of the evidence to support his conviction.  As discussed below, we have reviewed the record and conclude that the evidence is both legally and factually sufficient to support appellant=s conviction. 

I. Relevant Law

Section 19.02(b) of the penal code defines the offense of murder:

A person commits an offense if he:

(1) intentionally or knowingly causes the death of an individual; 

(2) intends to cause serious bodily injury and commits an act clearly dangerous to human life that causes the death of an individual; or

(3) commits or attempts to commit a felony, other than manslaughter, and in the course of and in furtherance of the commission or attempt, or in immediate flight from the commission or attempt, he commits or attempts to commit an act clearly dangerous to human life that causes the death of an individual.

Tex. Penal Code Ann. ' 19.02(b) (Vernon 2002).


In the case at bar, the jury charge authorized a conviction under the law of parties, even though the indictment did not specifically charge appellant under the law of parties.  Appellant now contends that the jury should not have been given the instruction.  This contention is not raised as a discrete issue but is made in appellant=s legal- and factual-sufficiency challenges.  Because we affirm the judgment of the trial court based on the legal and factual sufficiency of the evidence to establish appellant=s guilt as a party to the murder (and not as a principal), we note that the law of parties need not be pled in the indictment.  Vodochodsky v. State, 158 S.W.3d 502, 509 (Tex. Crim. App. 2005); Marable v. State, 85 S.W.3d 287 (Tex. Crim. App. 2002).  A defendant may be convicted based on the law of parties as long as the jury is given an adequate instruction on the law of parties.  Goff v. State, 931 S.W.2d 537, 544 (Tex. Crim. App. 1996).

Each party to an offense may be charged with the commission of the offense.  Tex. Penal Code Ann. ' 7.01(b) (Vernon 2003).  AA person is criminally responsible as a party to an offense if the offense is committed by his own conduct, by the conduct of another for which he is responsible, or by both.@  Id. ' 7.01(a).  The law of parties thus allows the State to enlarge a defendant=s criminal responsibility to acts in which he may not be the principal actor.  Goff, 931 S.W.2d at 544.  The following provision determines whether a person is criminally responsible for the conduct of another person:

(a)  A person is criminally responsible for an offense committed by the conduct of another if:

(1) acting with the kind of culpability required for the offense, he causes or aids an innocent or nonresponsible person to engage in conduct prohibited by the definition of the offense;

(2) acting with intent to promote or assist the commission of the offense, he solicits, encourages, directs, aids, or attempts to aid the other person to commit the offense; or

(3) having a legal duty to prevent commission of the offense and acting with intent to promote or assist its commission, he fails to make a reasonable effort to prevent commission of the offense.


Tex. Penal Code Ann. ' 7.02(a) (Vernon 2003).  As the court of criminal appeals recently explained, this provision establishes a party=s responsibility for the conduct of another based on the party=s Alevel of participation in the offense, even if he was not the proverbial triggerman.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Vodochodsky v. State
158 S.W.3d 502 (Court of Criminal Appeals of Texas, 2005)
Beier v. State
687 S.W.2d 2 (Court of Criminal Appeals of Texas, 1985)
Marable v. State
85 S.W.3d 287 (Court of Criminal Appeals of Texas, 2002)
McIntosh v. State
52 S.W.3d 196 (Court of Criminal Appeals of Texas, 2001)
Goff v. State
931 S.W.2d 537 (Court of Criminal Appeals of Texas, 1996)
Johnson v. State
23 S.W.3d 1 (Court of Criminal Appeals of Texas, 2000)
Sanders v. State
119 S.W.3d 818 (Court of Criminal Appeals of Texas, 2003)
Moreno v. State
755 S.W.2d 866 (Court of Criminal Appeals of Texas, 1988)
Ransom v. State
920 S.W.2d 288 (Court of Criminal Appeals of Texas, 1996)
Santellan v. State
939 S.W.2d 155 (Court of Criminal Appeals of Texas, 1997)
Cain v. State
976 S.W.2d 228 (Court of Appeals of Texas, 1998)
Clewis v. State
922 S.W.2d 126 (Court of Criminal Appeals of Texas, 1996)

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Bluebook (online)
Mark Rios v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mark-rios-v-state-texapp-2005.