Timothy Kion Huff v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMay 25, 2023
Docket02-22-00139-CR
StatusPublished

This text of Timothy Kion Huff v. the State of Texas (Timothy Kion Huff 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
Timothy Kion Huff v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________

No. 02-22-00139-CR ___________________________

TIMOTHY KION HUFF, Appellant

V.

THE STATE OF TEXAS

On Appeal from the 396th District Court Tarrant County, Texas Trial Court No. 1707472R

Before Kerr, Birdwell, and Walker, JJ. Memorandum Opinion by Justice Walker MEMORANDUM OPINION

I. INTRODUCTION

The State tried Appellant Timothy Kion Huff for committing a murder while

committing or attempting to commit a robbery—capital murder. See Tex. Penal Code

Ann. § 19.03(a)(2). The State presented evidence over five days, after which the

jury—deliberating for about an hour—found Huff guilty of capital murder.

Because the State sought the death penalty, Huff faced a punishment of life

imprisonment without parole or death. See id. § 12.31(b). The punishment trial

spanned another three days. After deliberating about seven hours, the jury

unanimously found beyond a reasonable doubt that

• there was a probability Huff would commit criminal acts of violence that would constitute a continuing threat to society, and

• Huff anticipated a human life would be taken.

But by a vote of at least ten jurors, the jury further found that

• taking into consideration all the evidence, including the offense’s circumstances, Huff’s character and background, and Huff’s personal moral culpability, a sufficient mitigating circumstance or sufficient circumstances warranted imposing a life-imprisonment-without-parole sentence rather than a death sentence.

In accordance with the jury’s verdict, the trial court sentenced Huff to life in prison

without parole. See id. § 12.31.

Huff appealed. On appeal, Huff raises two issues. He argues that

2 1. [t]he trial court’s jury charge [o]n guilt/innocence caused [him] egregious harm by permitting a guilty verdict for a crime not charged in the indictment[, and]

2. [t]he evidence is insufficient to hold [him] complicit as a party to a capital murder committed by another person while he was under arrest.

We overrule both issues and affirm the trial court’s judgment.

II. EVIDENTIARY SUFFICIENCY

Because Huff’s second issue, his sufficiency complaint, would result in greater

relief if granted, we address it first. See Mixon v. State, 481 S.W.3d 318, 322 (Tex.

App.—Amarillo 2015, pet. ref’d).

In Huff’s second issue, he contends that he was already under arrest when the

murder occurred. According to Huff, his arrest effectively terminated his

participation in any criminal wrongdoing, so the evidence is necessarily insufficient to

show that he was a party to the capital murder. We are not persuaded.

A. STANDARD OF REVIEW

In our evidentiary-sufficiency review, we view all the evidence in the light most

favorable to the verdict to determine whether any rational factfinder could have found

the crime’s essential elements beyond a reasonable doubt. Jackson v. Virginia, 443 U.S.

307, 319, 99 S. Ct. 2781, 2789 (1979); Queeman v. State, 520 S.W.3d 616, 622 (Tex.

Crim. App. 2017). This standard gives full play to the factfinder’s responsibility to

resolve conflicts in the testimony, to weigh the evidence, and to draw reasonable

3 inferences from basic facts to ultimate facts. See Jackson, 443 U.S. at 319, 99 S. Ct. at

2789; Harrell v. State, 620 S.W.3d 910, 914 (Tex. Crim. App. 2021).

The factfinder alone judges the evidence’s weight and credibility. See Tex. Code

Crim. Proc. Ann. art. 38.04; Martin v. State, 635 S.W.3d 672, 679 (Tex. Crim. App.

2021). We may not re-evaluate the evidence’s weight and credibility and substitute

our judgment for the factfinder’s. Queeman, 520 S.W.3d at 622. Instead, we determine

whether the necessary inferences are reasonable based on the evidence’s cumulative

force when viewed in the light most favorable to the verdict. Braughton v. State,

569 S.W.3d 592, 608 (Tex. Crim. App. 2018); see Villa v. State, 514 S.W.3d 227, 232

(Tex. Crim. App. 2017) (“The court conducting a sufficiency review must not engage

in a ‘divide and conquer’ strategy but must consider the cumulative force of all the

evidence.”). We must presume that the factfinder resolved any conflicting inferences

in favor of the verdict, and we must defer to that resolution. Braughton, 569 S.W.3d at

608.

B. DISCUSSION

Huff’s focus is misplaced. The question is not whether his arrest terminated

his participation in the offense. Rather, the question is whether the murder was

committed in furtherance of the robbery and whether that murder should have been

anticipated as a result of carrying out the conspiracy to commit the robbery. See Tex.

Penal Code Ann. § 7.02(b). Huff’s ability to promote the offense might have ended,

but the consequences for his participation in the offense had not.

4 1. When Engaging in Armed Robbery or When Fleeing from an Armed Robbery, Conspirators Should Anticipate the Possibility of a Murder Occurring.

Case law bears out that the focus is on what Huff should have anticipated

when he and his other conspirators engaged in armed robbery. Evidence that a

defendant knew his co-conspirators might use guns when committing a robbery can

be sufficient to show that the defendant should have anticipated the possibility of a

murder occurring during the robbery. Gittens v. State, 560 S.W.3d 725, 736 (Tex.

App.—San Antonio 2018, pet. ref’d) (stating that jury could have reasonably

determined that defendant should have anticipated someone could be killed because

firearms were used during robbery); Love v. State, 199 S.W.3d 447, 454 (Tex. App.—

Houston [1st Dist.] 2006, pet. ref’d). Similarly, fleeing and using force to escape are

acts that a co-conspirator should contemplate when committing an armed robbery.

See Ford v. State, 507 S.W.2d 735, 736 (Tex. Crim. App. 1974) (stating that when a

conspirator kills someone while trying to escape, the other conspirators should have

reasonably contemplated that death and are thus all criminally responsible).

2. Abundant Evidence Supports the Implied Finding.

The evidence showed that three masked and armed robbers entered a bar and

ordered everyone to get down. The bartender said that one of the robbers pointed a

gun at her uncle’s (the bar owner’s) head. One patron described a robber waiving a

gun in his face, hitting him in the head with a pistol, and pushing him to the ground.

A second patron testified that a robber put a gun to her brother-in-law’s head and to

5 her husband’s back. A third patron said that the robbers pointed guns at everyone

there and told them to lie down. And a fourth patron related that a robber held a gun

up to his face and that when the robber later pushed him, he felt a gun on the back of

his head.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
English v. State
592 S.W.2d 949 (Court of Criminal Appeals of Texas, 1980)
Ford v. State
507 S.W.2d 735 (Court of Criminal Appeals of Texas, 1974)
Love v. State
199 S.W.3d 447 (Court of Appeals of Texas, 2006)
Montoya v. State
810 S.W.2d 160 (Court of Criminal Appeals of Texas, 1991)
Kirsch, Scott Alan
357 S.W.3d 645 (Court of Criminal Appeals of Texas, 2012)
Damian Lamon Murkledove v. State
437 S.W.3d 17 (Court of Appeals of Texas, 2014)
Kristopher Donald Mixon v. State
481 S.W.3d 318 (Court of Appeals of Texas, 2015)
Villa v. State
514 S.W.3d 227 (Court of Criminal Appeals of Texas, 2017)
Kerry Gittens v. State
560 S.W.3d 725 (Court of Appeals of Texas, 2018)
Braughton, Christopher Ernest
569 S.W.3d 592 (Court of Criminal Appeals of Texas, 2018)
Queeman v. State
520 S.W.3d 616 (Court of Criminal Appeals of Texas, 2017)

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