Tyriq Bradford v. the State of Texas

Texas Court of Appeals, 10th District (Waco)·Decided April 16, 2026·No. 10-25-00057-CR·Published

Opinion

Court of Appeals

Tenth Appellate District of Texas

10-25-00057-CR

Tyriq Bradford,

Appellant

v.

The State of Texas,

Appellee

On appeal from the

361st District Court of Brazos County, Texas Judge David G. Hilburn, presiding Trial Court Cause No. 22-03641-CRF-361

JUSTICE SMITH delivered the opinion of the Court.

MEMORANDUM OPINION

A jury found Tyriq Bradford guilty of the offense of aggravated sexual assault of a child and assessed his punishment at life in prison. 1 See TEX. PENAL CODE ANN. § 22.021. In one issue on appeal, Bradford challenges the trial court’s admission, over his hearsay and confrontation objections, of

1 Based on the circumstances as indicted, this offense was punishable by a minimum of twenty-five

years in prison without the possibility of parole. See TEX. PENAL CODE ANN. § 22.021(f)(2); TEX. GOV’T CODE ANN. § 508.145(a)(4).

testimony and video evidence of the complainant’s three out-of-court statements to her mother identifying Bradford as the perpetrator of the offense.2 We affirm. RELEVANT BACKGROUND On July 4, 2022, six-year-old B.M. went missing while playing hide-and-

seek with other children near her home. Her mother and several others began searching for her. Bradford eventually carried B.M. home. She was wrapped up in a blanket and she was naked from the waist down.

The State designated B.M.’s mother as the outcry witness under article 38.072 of the Code of Criminal Procedure. See TEX. CODE CRIM. PROC. ANN. art. 38.072. At a pretrial hearing, the trial court made the preliminary finding that the State complied with the notice requirements of article 38.072 and questioned whether B.M. would be available to testify at trial. Id. at §§ 2(b)(1), 2(b)(3). The State explained that B.M. would be called as a witness, but noted that she may not be able to “engage in meaningful direct or cross-examination with regard to the substance of this case.”3

2 An issue is multifarious when it raises more than one specific complaint, and we are permitted to

reject multifarious issues on that basis alone. See Mays v. State, 318 S.W.3d 368, 385 (Tex. Crim. App. 2010); Wood v. State, 18 S.W.3d 642, 649 n. 6 (Tex. Crim. App. 2000). This issue is multifarious because it addresses two distinct complaints about three different statements admitted into evidence through multiple sources. However, in the interest of justice, we will address each of Bradford’s arguments.

3 B.M.’s mother later testified that B.M. had not been able to discuss the incident with any adult since B.M. told her what Bradford did.

Tyriq Bradford v. The State of Texas Page 2

During the pretrial hearing, B.M.’s mother described the scene after Bradford brought B.M. home. She explained that B.M. was emotional, crying, and in pain as she held the child on the porch. Many bystanders were crying and yelling in both Spanish and English. Without being prompted, B.M. told her mother in Spanish, “[I]t was Tyriq. He had a mask and he wanted to kill me.” The body camera of a nearby law enforcement officer also captured this statement and the video clip was admitted at the hearing. B.M.’s mother explained that B.M. was subsequently transported to a hospital in College Station. While there, she spontaneously told her mother, “it was Tyriq, Mommy, Tyriq.” Due to extensive physical injuries, B.M. was transferred to a different hospital in Temple the next day for an additional forensic medical exam and a surgical procedure. Her mother testified that prior to her surgery, B.M. was still emotional and in pain from the assault when she demonstrated with her hands what Bradford did to her, stating, “Tyriq had done like this in my parts (demonstrating) … ‘my little ass.’”

After the hearing, the trial court found all three statements were reliable based on time, content, and circumstances, noting that whether the statements were ultimately admissible under article 38.072 hinged on whether B.M. was available for cross-examination at trial. See id. at §§ 2(b)(2), 2(b)(3).

At trial, the State’s first witness was the Sexual Assault Nurse Examiner (“SANE”) who conducted B.M.’s initial forensic medical examination at the College Station hospital. The SANE swabbed B.M.’s fingernails and mons and collected her t-shirt for DNA analysis. She described how B.M. was still crying and in pain despite having been administered pain medication, and explained that B.M. was unable to give a patient history “due to her condition” and discomfort. B.M. was covered in debris, her face and ears were swollen, her entire face was covered in petechiae, and clear fluid was “weeping” from her ears. The SANE described a “very defined line around her neck that was red above it,” which indicated that B.M. was strangled with a ligature. She also observed “many, many, many” scratches, bruises, and abrasions similar to “a rug burn” on much of B.M.’s body, which she found consistent with being dragged. There was fresh and dried blood around B.M.’s vaginal area and thighs and swelling to her external genitalia. Notably, B.M. also had a large laceration to her perineum, so extensive that it caused concern for internal injury.

The SANE from the Temple hospital testified next. She explained that she began taking photos of B.M. after she arrived. She described how “[B.M.] became completely inconsolable. She was grabbing her mom, crying. She would not let me near her.” She testified that B.M. had to be put under

anesthesia “to adequately assess her injury as well as her level of discomfort and pain. It was just required to perform the exam at baseline.” This nurse also discussed several of B.M.’s physical injuries, adding that her perineum laceration “extend[ed] from the outside all the way through up into her vagina and there was a - - which means that section of her hymen was completely missing as well,” requiring a surgical “pediatric OB/GYN repair.”

Outside of the jury’s presence, the State explained that it intended to call B.M.’s mother as its third witness and have her testify to B.M.’s three statements identifying Bradford as her assailant. The prosecutor expressed uncertainty about B.M.’s ability to testify during trial as required to make the mother’s testimony admissible under article 38.072. Instead, the State argued that the statements were admissible as excited utterances. Bradford objected that the statements were hearsay and that their admission would violate his right to confrontation because B.M. might not testify.

Ultimately, the trial court expressly declined to admit the statements under article 38.072; instead, the court admitted the statements as excited utterances and overruled Bradford’s hearsay and confrontation objections. Bradford was granted running objections and also re-urged his objections in front of the jury.

B.M.’s mother testified in front of the jury to all three of B.M.’s statements. The clip of the body camera video that captured B.M.’s first statement in Spanish was later admitted into evidence during the law enforcement officer’s testimony, over Bradford’s hearsay and confrontation objections.

Later during trial, the State called B.M. to testify. When asked whether she remembered a time when “something really bad happened” to her, she shook her head. She also shook her head when asked whether she remembered going to the hospital. Bradford’s attorney was then given an opportunity to cross-examine B.M. Defense counsel only asked questions unrelated to the criminal offense. ANALYSIS Regarding the interplay between excited utterances and testimonial hearsay, the Court of Criminal Appeals has explained that

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