Adam Anderson v. State, 13-15-00430-CR

Adam Anderson was convicted by a jury of continuous family violence (one count) and two counts of assault family violence; all counts were enhanced by habitual-offender allegations; court sentenced him to concurrent 50-year terms.
State proved the charged 2014 assaults with victim Vanessa Shaw’s testimony, police responses, and photographs of her injuries.
The State also introduced a certified 2012 assault judgment as a prior conviction; Shaw testified she and Anderson had been in a dating relationship in 2008, the incident underlying the 2012 conviction.
Defense sought a directed verdict after the State rested; the trial court declined to rule until after all evidence, and the defense then called Anderson, who testified. After the close of all evidence the court denied the directed-verdict motion.
On appeal Anderson argued (1) the court abused its discretion by refusing to rule on his directed-verdict motion after the State rested (claiming burden-shift and compulsion to testify), and (2) the court erred by admitting extrinsic testimony to show the prior conviction involved family violence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Anderson)	Held
Trial court refusal to rule on directed-verdict motion when State rested	Court may defer ruling; sufficiency challenge can be preserved later; defendant not compelled to present evidence	Refusal forced him to present evidence and testify, shifting burden and infringing right to remain silent	Overruled — error not preserved and, on the merits, no reversible error; defendant chose to testify
Admissibility of extrinsic evidence to establish prior offense was family violence	Prior judgment of assault + extrinsic evidence (victim testimony) may prove the prior was family-violence for enhancement under §22.01(b)(2)(A)	Only the prior judgment should be examined; extrinsic testimony impermissible to show prior involved family violence	Overruled — statute requires proof the prior assault was against a family/household or dating partner; judgment need not expressly state it, so extrinsic evidence is admissible

Moff v. State, 131 S.W.3d 485 (Tex. Crim. App. 2004) (legal-sufficiency challenge need not be preserved by directed-verdict motion)
Williams v. State, 937 S.W.2d 479 (Tex. Crim. App. 1996) (same principle on sufficiency preservation)
Miller v. State, 33 S.W.3d 257 (Tex. Crim. App. 2000) (court may not read additional requirements into statute)
Tillman v. State, 354 S.W.3d 425 (Tex. Crim. App. 2011) (abuse-of-discretion standard for evidentiary rulings)
Reynolds v. State, 423 S.W.3d 377 (Tex. Crim. App. 2014) (statutory interpretation: plain meaning controls unless absurd)