Adrian Quigley v. State
02-15-00441-CR
| Tex. App. | Mar 9, 2017Background
- On April 7, 2015, Richard Myles was shot and killed in his Lewisville apartment; four .45-caliber casings and missing cash and a marijuana-filled green bag were found at the scene.
- Witnesses saw two Black males flee the apartment; one appeared injured and later was identified as Adrian Quigley, who had blood on him and whose blood was found in the building and in a rental vehicle used as the getaway car.
- Quigley initially gave inconsistent statements, then admitted he and Demico Stanley (later identified as the shooter) went to sell marijuana, that Stanley fired the shots, and that Quigley took Myles’s money and marijuana bag and fled.
- An inmate (William Hill) testified that Quigley had earlier said he planned to rob Myles and tried to recruit Hill to knock Myles out; Hill declined. Quigley then enlisted Stanley the next day.
- Quigley was indicted for capital murder (murder in the course of committing robbery). The jury was instructed on party liability (aiding/encouraging and conspiracy theories) and convicted; the court sentenced Quigley to life without parole.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence (legal/factual) to support capital murder | State: Evidence supports conviction under party liability (aiding or conspiracy) because Quigley planned and participated in the robbery and should have anticipated violence. | Quigley: Evidence insufficient; challenges both legal and factual sufficiency (including that he did not anticipate murder). | Affirmed. Under Jackson, evidence sufficed—jury could find conspiracy to rob, that Stanley killed Myles in furtherance, and Quigley should have anticipated the murder. Factual-sufficiency claim rejected under Brooks. |
| Duress affirmative defense | Quigley: He acted under threat by Stanley (forced to take property and flee), so duress negates culpability for robbery-related conduct. | State: Evidence supports rejection of duress; Quigley planned the robbery and knew Stanley’s violent reputation. | Affirmed. The jury’s implicit rejection of duress was not against the great weight of the evidence. |
| Motion for mistrial based on admission of statements about Quigley’s prior record | Quigley: Video testimony contained an unredacted remark referencing prior arrests, violating a limine order and warranting mistrial. | State: Defense had reviewed the exhibit, agreed to redactions and to publishing the portions played; no timely objection was made. | Affirmed. Issue not preserved—defense waived by prior agreement and failure to object when excerpt played. |
| Jury charge error (instructing on murder theories not alleged in indictment) | Quigley: Abstract charge included murder theories (b(2), b(3)) beyond alleged b(1), causing egregious harm. | State: Application paragraphs for capital murder correctly tracked b(1); any error in abstract portion or lesser-included paragraphs was harmless. | Affirmed. Even if abstract instruction were erroneous, no egregious harm because application paragraphs correctly instructed on the charged theory and jury convicted the greater offense. |
| Speedy-trial claim | Quigley: Delay between arrest and trial violated speedy-trial right. | State: Claim not preserved and, alternatively, delay under seven months was not presumptively prejudicial. | Affirmed. Issue not preserved (no ruling/hearing on motion). On the merits (alternative analysis), delay under eight months not presumptively prejudicial. |
Key Cases Cited
- Clewis v. State, 922 S.W.2d 126 (Tex. Crim. App. 1996) (describing prior factual-sufficiency standard overruled by Brooks)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (holding Jackson is the sole standard for sufficiency review)
- Jackson v. Virginia, 443 U.S. 307 (1979) (establishing legal-sufficiency standard for criminal convictions)
- Tippitt v. State, 41 S.W.3d 316 (Tex. App.—Fort Worth 2001) (analyzed co-conspirator liability where defendant lacked knowledge of coconspirator’s violent propensities)
- Barker v. Wingo, 407 U.S. 514 (1972) (establishing the four-factor speedy-trial balancing test)
- Medina v. State, 7 S.W.3d 633 (Tex. Crim. App. 1999) (explaining that correct application paragraphs cure errors in abstract charge)