Abelino Hernandez v. State, 13-14-00465-CR

Appellant Abelino Hernandez was indicted for aggravated robbery (victim alleged elderly); trial took place August 2014; jury convicted him and judge sentenced him to 30 years after he pled true to two prior felony enhancements.
During guilt/innocence, Officer Holly Jedlicka testified about fingerprint evidence and the AFIS (Automated Fingerprint Identification System) database.
Jedlicka testified that prints are entered into AFIS when someone is booked into a jail facility; under questioning she agreed AFIS also contains prints from state employees and those who undergo background checks.
Defense objected to the AFIS testimony as unduly prejudicial; the trial court noted the objection but allowed the testimony to continue (citing Mata sua sponte on the record).
The fingerprint evidence actually showed that prints from the crime scene did not match Hernandez; appellant argues the AFIS testimony improperly suggested he had prior arrests/contacts with law enforcement and was therefore a "smear."

Issue	Plaintiff's Argument (Hernandez)	Defendant's Argument (State)	Held
Admission of testimony about AFIS and why prints are in it	AFIS testimony implied appellant was previously booked/arrested; zero probative value because prints did not match and testimony was unfairly prejudicial	AFIS testimony was explanatory; AFIS contains more than criminal prints (state employees, background checks), so no clear implication of criminal history	Trial court allowed the AFIS explanatory testimony over defense objection (appellant seeks reversal on this evidentiary ruling)

Erazo v. State, 144 S.W.3d 487 (Tex. Crim. App. 2004) (factors for reviewing unfairly prejudicial evidence admissibility)
Mozon v. State, 991 S.W.2d 841 (Tex. Crim. App. 1991) (standard for reversing trial court evidentiary rulings is rare and requires clear abuse of discretion)
Rogers v. State, 991 S.W.2d 263 (Tex. Crim. App. 1999) (definition of unfair prejudice as tendency to prompt decision on an improper basis)