The State of Texas v. Michael Ruscoe

CourtCourt of Appeals of Texas
DecidedMarch 21, 2025
Docket03-23-00186-CR
StatusPublished

This text of The State of Texas v. Michael Ruscoe (The State of Texas v. Michael Ruscoe) 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
The State of Texas v. Michael Ruscoe, (Tex. Ct. App. 2025).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-23-00186-CR

The State of Texas, Appellant

v.

Michael Ruscoe, Appellee

FROM THE 299TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-DC-21-900025, THE HONORABLE KAREN SAGE, JUDGE PRESIDING

MEMORANDUM OPINION

The State of Texas appeals from the district court’s order granting a new trial to

appellee Michael Ruscoe, who was convicted of murder. In its sole point of error, the State

asserts that the district court abused its discretion in granting a new trial. We will affirm the trial

court’s order.

BACKGROUND

The State charged Ruscoe with intentionally or knowingly causing the death of

Derrick Amoriko by shooting him with a firearm. Some of the circumstances surrounding the

shooting were undisputed at trial, including that the shooting occurred during a child-custody

dispute between Amoriko and Ruscoe’s then-girlfriend, Ruth Berny (who is now Ruscoe’s wife),

involving Amoriko and Berny’s three-year-old daughter. On the day of the shooting, Ruscoe

drove Berny to Amoriko’s house with the intent to take custody of the child, who was staying

with Amoriko at the time. When they arrived at the house and confronted Amoriko, an argument ensued. During the argument, Amoriko attempted to leave his house with the child in his

vehicle. Ruscoe and Berny were able to get into the vehicle before Amoriko drove away, and

Amoriko proceeded to drive erratically through his neighborhood before returning to his house,

parking in the garage, and exiting the vehicle, yelling at Ruscoe and Berny to get out of his car.

Amoriko then attacked Ruscoe and Berny with a sledgehammer, striking Ruscoe in the leg with

it. Ruscoe then ran to his vehicle that was parked on the street, retrieved a handgun, and ran

back toward the garage, where Amoriko, Berny, and the child were still located. Shortly

thereafter, Ruscoe shot Amoriko in the chest, killing him.

Ruscoe’s vehicle had a dash camera that recorded some of the events immediately

before, during, and after the shooting. The camera was facing the street and did not show the

garage, so there was no video recording showing the shooting itself. However, the video

recording did show Ruscoe running toward his vehicle, retrieving the gun, and running back

toward the garage. Additionally, on the audio portion of the recording, Berny can be heard

screaming and crying, Amoriko can be heard yelling at Ruscoe and Berny to get out of his car,

and then, after Ruscoe had retrieved the gun, Ruscoe can be heard telling Amoriko, “Back the

fuck up.” Amoriko asked Ruscoe, “Are you going to shoot me on my own property?” Ruscoe

responded, “I will.” Then a gunshot can be heard. Immediately after that, Ruscoe can be heard

yelling, “Back the fuck up! Back the fuck up! Let her go!” Finally, before the recording ends,

Berny can be seen running toward Ruscoe’s vehicle, holding the child.

The central issue at trial was whether Ruscoe was justified in shooting Amoriko.

The defense’s theory of the case was that Ruscoe shot Amoriko in either self-defense or Berny’s

defense. Ruscoe and Berny each testified that before Ruscoe shot Amoriko, Amoriko had

grabbed Berny by her hair and throat and had her in a chokehold. Berny also testified that

2 Amoriko was threatening to kill them while he attacked them with a sledgehammer. Ruscoe

testified that he believed Amoriko was going to kill either him or Berny if Ruscoe “didn’t

do something.”

The State’s theory of the case was that Amoriko was not attacking anyone when

Ruscoe shot him. A neighbor who had witnessed the shooting from a few houses down and

across the street from Amoriko’s house testified that before Ruscoe shot Amoriko, Amoriko

stood “with his hands down to his side, like what’s up.” According to this neighbor, Berny was

located “about three and a half feet away from” Amoriko, “just standing there” and holding the

child. Another neighbor who also witnessed the shooting from the nearby house

testified similarly.1

The State charged Ruscoe with the murder of Amoriko, and the jury received

instructions on self-defense, defense of a third person, and necessity. The jury found Ruscoe

guilty of murder as charged. Following the hearing on punishment, the district court found that

Ruscoe had acted under the immediate influence of sudden passion arising from an adequate

cause, which reduced the offense to a second-degree felony, and sentenced him to the statutory

minimum of two years’ imprisonment. See Tex. Penal Code § 19.02(d).

Ruscoe filed both a notice of appeal and a motion for new trial that he later

amended. In the amended motion, Ruscoe raised ten grounds for granting a new trial: ground

one alleged that the State failed to discover and disclose Amoriko’s previous acts of violence and

1 The two neighbors, along with a third neighbor, were standing outside and on or near the neighbor’s driveway when the shooting occurred. The view from the neighbor’s garage could be seen on a video recording taken from one of the neighbors’ security cameras. A portion of Amoriko’s driveway is visible from the camera, and Ruscoe can be seen running to his car and then running back up the driveway. Then, yelling and screaming can be heard, followed by a gunshot. However, the shooting itself cannot be seen from the camera angle.

3 other bad acts committed against Berny and other women, in violation of Brady v. Maryland,

373 U.S. 83, 87 (1963); grounds two through nine alleged that trial counsel was ineffective for

failing to investigate and present to the jury Amoriko’s previous bad acts and other evidence; and

ground ten alleged that Ruscoe was “actually innocent” of the charged offense based on newly

discovered evidence.

All the claims were based on evidence that was not presented to the jury during

trial, either because “it was not disclosed by the prosecutors, because it was not discovered by

trial counsel, or because it was not presented by trial counsel.” Ruscoe alleged that the following

evidence (admitted at the motion-for-new-trial hearing as Defense Exhibits A through G), was

“not disclosed by prosecutors, nor discovered by trial counsel, until after sentencing”:

The information in Austin Police Department (“APD”) offense report GO# 2019- 1891242, relating to Amoriko assaulting Berny (contained in Exhibit A);

The information in APD offense report GO# 2015-3440056, relating to Amoriko assaulting a woman named Rachel Legsdin (contained in Exhibit B);

The information in APD offense report GO# 2014-5045822, relating to Amoriko screaming at a female employee to the degree she called 311 (contained in Exhibit C);

The information in APD offense report GO# 2006-1961536, relating to Amoriko harassing Lori King after she broke up with Amoriko and moved out (contained in Exhibit D);

The information in APD offense report GO# 2003-2150233, relating to Amoriko assaulting his wife, Tatyana (contained in Exhibit E);

4 The information in APD offense report GO# 2003-2370299, relating to Amoriko appearing at Tatyana’s residence and frightening her to the degree she called the police (contained in Exhibit F).

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
Kyles v. Whitley
514 U.S. 419 (Supreme Court, 1995)
Strickler v. Greene
527 U.S. 263 (Supreme Court, 1999)
Banks v. Dretke
540 U.S. 668 (Supreme Court, 2004)
Youngblood v. West Virginia
547 U.S. 867 (Supreme Court, 2006)
Madden v. State
242 S.W.3d 504 (Court of Criminal Appeals of Texas, 2007)
State v. Williams
83 S.W.3d 371 (Court of Appeals of Texas, 2002)
Hayes v. State
85 S.W.3d 809 (Court of Criminal Appeals of Texas, 2002)
Bass v. State
270 S.W.3d 557 (Court of Criminal Appeals of Texas, 2008)
State v. Herndon
215 S.W.3d 901 (Court of Criminal Appeals of Texas, 2007)
Harm v. State
183 S.W.3d 403 (Court of Criminal Appeals of Texas, 2006)
State v. Moore
240 S.W.3d 324 (Court of Appeals of Texas, 2007)
De La Paz v. State
279 S.W.3d 336 (Court of Criminal Appeals of Texas, 2009)
Ex Parte Kimes
872 S.W.2d 700 (Court of Criminal Appeals of Texas, 1993)
Riley, Billy Dee Jr.
378 S.W.3d 453 (Court of Criminal Appeals of Texas, 2012)
State of Texas v. Thomas, Jeremy
428 S.W.3d 99 (Court of Criminal Appeals of Texas, 2014)
State v. Gutierrez
541 S.W.3d 91 (Court of Criminal Appeals of Texas, 2017)

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