Artavious Deon Hollins v. State, 01-14-00745-CR

Artavious Deon Hollins was indicted for murder and tampering with evidence; tried before a jury and convicted of both; sentenced to life for murder and 25 years for tampering; appeal filed.
Central disputed factual issue: whether Hollins retreated into his apartment and was attacked there (claiming self‑defense) or whether he invited the other men in and was the aggressor.
Witnesses agreed there was a struggle over a gun inside Hollins’ apartment and the gun discharged; testimony conflicted about who brought the gun and who entered first.
A mud/footprint photograph on Hollins’ apartment door (State’s Exhibit 17) was used by the prosecution to suggest the print was old, undermining Hollins’ claim that the men kicked his door in shortly before the shooting.
Defense objected when a crime scene officer testified (over objection) that the footprint had been there long enough to dry; defense argued the officer was speculating and lacked personal knowledge under Tex. R. Evid. 602.
Defense also argued the evidence was legally insufficient to support a murder conviction because the shooting occurred during a struggle after Hollins had been harassed and retreated, and the record did not support the requisite intent or a clearly dangerous act beyond reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of testimony that footprint was "old/dry"	Officer’s training/experience allowed him to infer age of print; evidence relevant to credibility of Hollins’ self‑defense claim	Officer lacked personal knowledge; testimony was speculative under Rule 602 and improperly vouched the State’s theory	Trial court allowed the testimony over objection (defendant urges abuse of discretion); appellant argues this was reversible error
Sufficiency of evidence for murder conviction	Evidence (struggle, shooting) supports a finding Hollins knowingly/ intentionally caused death; jury credited State witnesses	Even viewed favorably to State, testimony shows struggle/ accidental discharge during self‑defense and Hollins lacked intent; no rational trier could find murder beyond a reasonable doubt	Appellant contends evidence legally insufficient and seeks reversal and acquittal or new trial

Bigby v. State, 892 S.W.2d 864 (Tex. Crim. App. 1994) (personal knowledge requirement for witnesses under Rule 602)
Willover v. State, 70 S.W.3d 841 (Tex. Crim. App. 2002) (abuse of discretion standard for trial‑court evidentiary rulings)
Walters v. State, 247 S.W.3d 204 (Tex. Crim. App. 2007) (review of trial‑court rulings and "zone of reasonable disagreement")
Falrow v. State, 943 S.W.2d 895 (Tex. Crim. App. 1997) (personal knowledge derived from senses or experience)
Wise v. State, 364 S.W.3d 900 (Tex. Crim. App. 2012) (Jackson‑v‑Virginia standard and appellate review of sufficiency)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard of review for sufficiency challenges)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (constitutional standard for sufficiency of the evidence)
Forest v. State, 989 S.W.2d 365 (Tex. Crim. App. 1999) (firing a gun in the direction of someone as an act dangerous to human life)
Cantu v. State, 395 S.W.3d 202 (Tex. App.—Houston [1st Dist.] 2012) (comparison on accidental discharge/staged evidence issues)