Trenton James Adams v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJune 26, 2025
Docket10-24-00041-CR
StatusPublished

This text of Trenton James Adams v. the State of Texas (Trenton James Adams 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
Trenton James Adams v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

Court of Appeals Tenth Appellate District of Texas

10-24-00041-CR

Trenton James Adams, Appellant

v.

The State of Texas, Appellee

On appeal from the 443rd District Court of Ellis County, Texas Hon. Cynthia Ermatinger, presiding Trial Court Cause No. 47273CR

JUSTICE SMITH delivered the opinion of the Court.

MEMORANDUM OPINION

A jury convicted Trenton James Adams of capital murder. See TEX.

PENAL CODE ANN. § 19.03(a)(2). The trial court assessed his punishment at

life in prison without parole. In his sole issue on appeal, Adams contends that

the trial court erred by denying his request for a jury charge instruction on the

affirmative defense of insanity. We affirm. RELEVANT BACKGROUND

Adams and his friend, Jordan von Hoffman, were remodeling a trailer in

Ellis County, Texas where Adams planned to live with his girlfriend. In March

of 2021, von Hoffman’s body was found in a shed behind the trailer, wrapped

in a tarp and packed inside of a barrel. He had been hogtied and his clothes

had been cut off of his body. The medical examiner determined von Hoffman’s

cause of death to be homicidal violence through a combination of blunt force

injuries and neck compression. Adams was charged with capital murder for

intentionally causing von Hoffman’s death in the course of committing or

attempting to commit the offense of kidnapping. See id.

Prior to trial, Adams filed notice of his intent to raise the affirmative

defense of insanity. See TEX. CODE CRIM. PROC. ANN. art. 46C.051. At the

charge conference, the State objected to the inclusion of an insanity defense

instruction in the jury charge.1 Defense counsel argued that the instruction

should be included in the charge because evidence was presented that Adams

had family history of mental illness, was prescribed medication for psychosis

both before and after the offense, and was acting irrationally both before and

after the offense. The trial court denied the requested instruction, finding that

1 It appears from the discussion on the record that a preliminary version of the charge was prepared

prior to the charge conference that included an insanity defense instruction. A copy of this version of the charge is not in the record.

Trenton James Adams v. The State of Texas Page 2 “there is no evidence in the record to even suggest that […] Trenton Adams did

not know right from wrong at the time he committed the offense.”

AUTHORITY

“A defendant is entitled to an instruction on [a defensive issue] if the

issue is raised by the evidence, whether that evidence is strong or weak,

unimpeached or contradicted, and regardless of what the trial court may think

about the credibility of the defense.” Ferrel v. State, 55 S.W.3d 586, 591 (Tex.

Crim. App. 2001). We review a trial court’s decision not to include a defensive

issue in the jury charge for an abuse of discretion and view the evidence in the

light most favorable to the requested instruction. See Wesbrook v. State, 29

S.W.3d 103, 122 (Tex. Crim. App. 2000); Bufkin v. State, 207 S.W.3d 779, 782

(Tex. Crim. App. 2006).

The affirmative defense of insanity is found in Section 8.01 of the Texas

Penal Code, which provides:

It is an affirmative defense to prosecution that, at the time of the conduct charged, the actor, as a result of severe mental disease or defect, did not know that his conduct was wrong.

TEX. PENAL CODE ANN. § 8.01(a). The issue of a defendant’s insanity must be

submitted to the jury only if the issue is supported by competent evidence. See

TEX. CODE CRIM. PROC. ANN. art. 46C.151(a).

Trenton James Adams v. The State of Texas Page 3 DISCUSSION

The parties agree that the record contains some evidence that Adams

suffered from a mental disease or defect. At trial, Adams called as witnesses

several family members, one of his grandparents’ neighbors, and psychologist

Dr. William Flynn in support of his insanity defense. Dr. Flynn did not

personally interview Adams or perform an insanity evaluation on him, but he

reviewed some of Adams’s medical records. Dr. Flynn testified that according

to the medical records, Adams had been prescribed medication for psychosis in

2016 and 2017. After he arrived at the Ellis County Jail in July of 2021, Adams

requested multiple times to see a doctor because he was having suicidal

thoughts and hearing a voice called “James.” He was eventually diagnosed

with unspecified anxiety disorder and schizoaffective disorder and was

prescribed medication for psychosis. Several family members testified to

Adams’s family history of severe mental illness and his own bizarre behavior,

including two incidents about a week and a half before the murder. In one

instance, on March 11, 2021, Adams showed up at his uncle’s place of work

acting angry and irrational. In another instance, Adams knocked on the door

of one of his grandparents’ neighbor’s, whom he had never spoken with, and

began nonsensically yelling.

Trenton James Adams v. The State of Texas Page 4 While an insanity defense requires proof of a mental disease or defect,

the issue of insanity is not strictly medical. See Bigby v. State, 892 S.W.2d 864,

877 (Tex. Crim. App. 1994); Graham v. State, 566 S.W.2d 941, 949 (Tex. Crim.

App. 1978). It also contains a legal or ethical component that requires evidence

that the defendant did not know his conduct was wrong due to his mental

disease or defect. See Bigby, 892 S.W.2d at 877-78. Adams points to one of his

many proffered motives for murdering von Hoffman – namely, that he killed

von Hoffman for allegedly molesting his girlfriend’s child – to argue that he did

not understand his conduct was wrong because “due to his mental disease or

defect, [he] believed he was morally justified in committing the offense[.]”

However, in the context of an insanity defense, the term “wrong” refers

to the defendant’s understanding of the legality of his actions, not the morality

of his actions. See Ruffin v. State, 270 S.W.3d 586, 592 (Tex. Crim. App. 2008).

In other words, “the question for deciding insanity is this: Does the defendant

factually know that society considers this conduct against the law, even though

the defendant, due to his mental disease or defect, may think that the conduct

is morally justified?” Id. Thus, even if Adams thought he was morally justified

in murdering von Hoffman, an insanity defense was raised only if the record

contains some evidence that, due to his mental disease or defect, Adams did

not understand that murdering von Hoffman was against the law.

Trenton James Adams v. The State of Texas Page 5 The record contains several possible motives and explanations for von

Hoffman’s murder, including that Adams murdered von Hoffman in retaliation

for allegedly molesting a child, or as part of a ritualistic blood sacrifice, or

possibly as revenge for Adams’s girlfriend allegedly cheating on him with von

Hoffman. Adams also once claimed that he was forced to dispose of von

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Related

Wesbrook v. State
29 S.W.3d 103 (Court of Criminal Appeals of Texas, 2000)
Ruffin v. State
270 S.W.3d 586 (Court of Criminal Appeals of Texas, 2008)
Bigby v. State
892 S.W.2d 864 (Court of Criminal Appeals of Texas, 1994)
Graham v. State
566 S.W.2d 941 (Court of Criminal Appeals of Texas, 1978)
Bufkin v. State
207 S.W.3d 779 (Court of Criminal Appeals of Texas, 2006)
Ferrel v. State
55 S.W.3d 586 (Court of Criminal Appeals of Texas, 2001)

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