Victor Hamilton v. State

563 S.W.3d 442
CourtCourt of Appeals of Texas
DecidedOctober 25, 2018
Docket01-17-00461-CR
StatusPublished
Cited by9 cases

This text of 563 S.W.3d 442 (Victor Hamilton 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
Victor Hamilton v. State, 563 S.W.3d 442 (Tex. Ct. App. 2018).

Opinion

Opinion issued October 25, 2018

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-17-00461-CR ——————————— VICTOR HAMILTON, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 209th District Court Harris County, Texas Trial Court Case No. 1458269

OPINION

Victor Hamilton was indicted for the felony offense of aggravated robbery. A

jury found him guilty as charged and sentenced him to 35 years’ confinement. On

appeal, Hamilton contends that the trial court erred in denying his request for a jury instruction on the lesser-included offense of robbery and denying a hearing on his

motion for new trial. We affirm.

BACKGROUND

Hamilton entered a Walmart in northern Harris County, approached a store

associate in the electronics department, and asked her if the store had any tablet

computers in stock. The associate replied that she would check the stockroom, and

she headed toward the back of the store.

Unbeknownst to the associate, Hamilton followed her past the customer area

into the stockroom. When the associate unlocked the gate to the stockroom cage

area where the electronics were stored, she felt someone brush past her shoulder. In

a low voice, Hamilton told her that he had a gun and ordered her to stand still with

her hands up. Hamilton then moved where the associate could see him. He lifted

the bottom hem of his shirt to show her that he had his hand on a black handgun

tucked inside the waistband of his pants. Hamilton pulled a beige duffel bag out of

his pants, adjusted the gun so that it was snug inside his waistband, then pulled his

shirt down over the gun. Then, he began to take electronics equipment from the

shelf and load it into the bag. At some point, the associate started to lower her hands;

Hamilton placed his hand on the gun again and threatened, “Hey, I thought I told

you not to move.”

2 When Hamilton had filled the bag, he rushed out of the stockroom and into

the hall. He turned toward a double-door fire exit and started kicking the doors. The

associate ran out of the storage room and into a maintenance closet, where she hid

with other employees.

A Walmart loss-prevention officer in an office across the hall from the fire

exit heard banging on the doors and ran to investigate. As the fire alarm sounded,

the officer saw a man with a bag run out the fire exit and into the loading dock area.

She followed about ten feet behind him to observe his actions. As the man continued

his flight, he dodged in between truck trailers until he reached a gray Nissan sedan

that had been parked behind them. As the man drove away, the officer wrote down

his license plate number. After recording the number, the officer noticed an object

on the pavement beside one of the trailers. She retrieved the object, which turned

out to be a cell phone. She did not find a gun, see the man drop a gun, or notice

whether he had a gun. The man did not turn around during his flight; the loss-

prevention officer never saw his face. She was unable to identify Hamilton in court.

The loss-prevention officer gave the cell phone to a manager. She completed

an incident report, collected surveillance video from the store’s security cameras,

and compiled video showing the incident. She also compiled a list of missing

electronics inventory by comparing the serial numbers on the inventory remaining

in the stockroom with those recorded in the previous day’s inventory log.

3 Security video recordings from several cameras inside the store’s main floor

and outside of the store showed Hamilton before, during, and after his interaction

with the electronics associate. Video recorded inside the storage room does not show

Hamilton and the employee completely inside the frame. The camera was anchored

high on a wall and was some distance from the electronics area. The low-resolution

video shows Hamilton obscured by boxes, or with his back and side facing the

camera as he put the electronics into his bag. It does not show his front mid-section,

or a gun.

The retrieved cell phone was locked, so the loss-prevention officer removed

the SD card from the phone and inserted it into a computer device that was able to

read the data stored on the SD card. With information and images recovered from

the phone, the electronics associate applied the lessons she learned in her criminal

justice studies classes to locate Hamilton’s Facebook page.

Harris County deputy constables dispatched to Walmart interviewed the

electronics associate and the loss-prevention officer. The loss-prevention officer

gave them the surveillance video; the cell phone’s SD card; the cell phone; a photo

disc containing copies of the photos stored on the phone; the loss-prevention report;

and itemized receipts for the missing inventory. The loss-prevention officer also

provided information concerning the make, model, and license plate number of the

car Hamilton used to escape.

4 The constables found some of the stolen tablets at nearby pawn shops. They

presented a photo array to two pawnshop owners. Each identified Hamilton as the

person who pawned the tablets.

Proceedings below

During the charge conference, Hamilton asked the trial court to submit an

instruction on the lesser-included offense of robbery by threat. The trial court denied

the request.

Post-verdict, Hamilton moved for a new trial, contending that the trial court

improperly denied his request to instruct the jury on the lesser-included offense of

robbery and that new evidence had come to light. Hamilton included three affidavits

with his motion. In the first, his brother attested that he had been with Hamilton

immediately before the alleged aggravated robbery, Hamilton was not carrying a

weapon at that time, and Hamilton did not usually carry a gun. Hamilton’s mother

and wife executed the other two affidavits. They described his difficult childhood

and his mental illness.

The trial court did not grant a hearing on Hamilton’s motion for new trial, and

the motion was overruled by operation of law. See TEX. R. APP. P. 21.8.

5 DISCUSSION

I. Refusal to Submit Robbery as a Lesser-included Offense

Hamilton first contends that the trial court erred in failing to instruct the jury

on the lesser-included offense of robbery.

A. Standard of review and applicable law

We apply a two-pronged test to determine whether Hamilton was entitled to a

charge on a lesser-included offense. See Young v. State, 283 S.W.3d 854, 875 (Tex.

Crim. App. 2009). We initially consider whether the offense contained in the

requested instruction is a lesser-included offense of the charged offense. Goad v.

State, 354 S.W.3d 443, 446 (Tex. Crim. App. 2011). If it is, we decide whether the

admitted evidence supports the instruction. Id.

An offense is a lesser-included offense if:

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563 S.W.3d 442, Counsel Stack Legal Research, https://law.counselstack.com/opinion/victor-hamilton-v-state-texapp-2018.