Antonio Patterson v. State, 05-13-00450-CR

On Feb. 27, 2010, William Artis was robbed, shot, placed in the trunk of his car, and the car set on fire; he survived with severe injuries.
James Collins (accomplice) testified he helped set up Artis, that appellant Antonio Patterson struck Artis, put him in the trunk, shot into the trunk, poured gasoline, and ignited the car; Collins admitted plea-related benefits for his testimony.
Artis (victim) identified a “big dude” as the assailant in a recorded interview and in a photographic lineup; his in-court identification was impaired by injuries.
Cell phone records showed calls between Patterson and Collins shortly before the fire; tower data placed calls on a tower ~0.7 mile from the burning-car location.
Patterson was convicted by a jury of aggravated robbery with a deadly weapon and received life imprisonment; he appealed raising (1) insufficiency of corroboration for the accomplice testimony and (2) trial-court error in admitting testimony interpreting cell-phone records without a Daubert hearing.

Issue	State's Argument	Patterson's Argument	Held
Sufficiency: whether accomplice testimony (Collins) was sufficiently corroborated	Non-accomplice evidence (Artis’s statements/lineup ID, phone records, tower maps) tends to connect Patterson to the offense	Collins’s testimony was uncorroborated; Artis’s testimony only placed Patterson at scenes but did not show he committed shooting, robbery, or arson	Affirmed: after excluding accomplice testimony, remaining evidence could rationally tend to connect Patterson to the offense, satisfying Tex. Code Crim. Proc. art. 38.14 standard
Admissibility: whether court erred in refusing a Daubert hearing before allowing testimony interpreting cell-phone records/maps	Detective Franco’s mapping/interpretation merely explained information in admissible records; testimony was understandable to jurors and not dispositive; qualifications and reliability were within trial-court discretion	Court should have held a Daubert/Kelly hearing and excluded expert interpretation because Franco’s qualifications re: cell-tower radius/forensics were not shown	Affirmed: trial court did not abuse discretion admitting the testimony; mapping was not technically complex, testimony was not conclusive, and it tended to connect Patterson to scene

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (Jackson review applied in Texas)
Smith v. State, 332 S.W.3d 425 (corroboration standard for accomplice testimony)
Daubert v. Merrell Dow Pharm., 509 U.S. 579 (gatekeeping for expert scientific evidence)
Kelly v. State, 824 S.W.2d 568 (Texas standard for expert admissibility)
Rodgers v. State, 205 S.W.3d 525 (qualification/reliability/relevance triad for expert testimony)
Vela v. State, 209 S.W.3d 128 (degree of expertise required relates to complexity of field)
Sexton v. State, 93 S.W.3d 96 (abuse-of-discretion review for expert-admissibility rulings)