Angel Lee Bryan v. State, 09-15-00213-CR

Angel Lee Bryan was convicted by a jury of murder and sentenced to 20 years’ imprisonment for the death of her adopted niece, P.B., a nineteen-month-old who died of blunt-force head injuries.
Medical testimony (pediatrician, emergency physician, and medical examiner) established a healed and acute occipital skull fracture, multilayer subdural hematoma, retinal/nerve-sheath hemorrhages, and that death resulted from acute on chronic subdural hemorrhage due to blunt-force head injuries; manner of death: homicide.
Forensic analysis showed a two- to three-week-old skull fracture and a two- to three-week-old rib fracture; hair fragments found in a crack in the wall were consistent with P.B.’s hair.
Witnesses placed Bryan as primary caregiver; other witnesses described Bryan’s drug use in the home and circumstances (cracked paneling and damaged baby bed) consistent with head impact against hard surfaces.
Bryan initially gave varying accounts of how the injury occurred (other child found P.B.; later said she tripped and fell with P.B.) and lied about who found the child; she was arrested after P.B. died.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove Bryan knowingly/intentionally caused death by striking or violently shaking the child	State: medical, forensic, and circumstantial evidence show adult-inflicted blunt-force trauma and prior injuries inconsistent with accidental causes	Bryan: evidence insufficient to prove she acted knowingly/intentionally or that injuries were inflicted by her rather than accidental or by others	Court: Affirmed—viewing all evidence in the light most favorable to the verdict, a rational juror could find guilt beyond a reasonable doubt

Jackson v. Virginia, 443 U.S. 307 (1979) (establishes standard for legal-sufficiency review — whether any rational jury could find guilt beyond reasonable doubt)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (explains appellate review of sufficiency and deference to jury credibility determinations)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (affirms deference to jury in resolving evidentiary conflicts)
Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (addresses reasonable inferences from combined evidence in sufficiency review)
Geesa v. State, 820 S.W.2d 154 (Tex. Crim. App. 1991) (circumstantial evidence can be sufficient; appellate review does not require exclusion of every reasonable hypothesis of innocence)
Penagraph v. State, 623 S.W.2d 341 (Tex. Crim. App. 1981) (jury is sole judge of witness credibility and weight of testimony)