Brandon Joseph Williams v. State
502 S.W.3d 262
| Tex. App. | 2016Background
- Appellant Brandon Joseph Williams shot and killed Veta Karla Conrad while living at his mother Sue’s house; he does not dispute firing the shot but contests whether he formed the requisite intent to murder.
- Williams had used drugs (synthetic marijuana/Kush and methamphetamine) shortly before the shooting; he exhibited elevated vitals and received emergency treatment.
- After the shooting Williams gave a 72‑minute videotaped interview about twelve hours later in which he described hearing voices, fighting with the devil, using drugs, and acknowledged that he fired one round; he did not request counsel.
- Williams was convicted by a jury of murder and sentenced to 67 years’ confinement and a $10,000 fine; he appealed raising four issues.
- Appellate issues: (1) sufficiency of evidence to show mens rea given alleged PTSD; (2) denial of motion to suppress videotaped statement as involuntary; (3) exclusion of expert testimony on alleged mental illnesses at guilt/innocence phase; (4) refusal to give various lesser‑included offense instructions.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence of murder mens rea | PTSD and intoxication prevented formation of intent to kill | Use of a firearm in a deadly manner permits an inference of intent; evidence supports knowing/intentional shooting | Affirmed — evidence sufficient to infer intent from deadly‑weapon use |
| Motion to suppress videotaped confession | Statement involuntary because of PTSD, hallucinations, intoxication, medications | Video and testimony show Williams sought the interview, understood Miranda warnings, communicated coherently, and did not appear intoxicated or delusional during interview | Affirmed — trial court did not abuse discretion; waiver was knowing, intelligent, voluntary |
| Exclusion of expert mental‑health testimony at guilt phase | Experts would show PTSD/psychosis that negated mens rea (diminished capacity) | Proffered testimony did not address or negate ability to form intent or knowledge of conduct; irrelevant to mens rea | Affirmed — exclusion proper because proffer did not negate the required culpable mental state |
| Lesser‑included offense instructions | Evidence warranted instructions on voluntary manslaughter, negligent homicide, aggravated assault, deadly conduct | No record citations or specific germane evidence provided; appellant’s briefing inadequate | Affirmed — issue waived/inadequately briefed; no preserved showing of evidence germane to lesser offenses |
Key Cases Cited
- Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (distinguishes insanity defense from diminished‑capacity evidence and permits expert evidence that negates mens rea)
- Jackson v. State, 160 S.W.3d 568 (Tex. Crim. App. 2005) (diminished‑capacity evidence is admissible when it directly rebuts mens rea)
- Mays v. State, 318 S.W.3d 368 (Tex. Crim. App. 2010) (mental illness that explains motive or influence does not necessarily negate intent)
- Cavazos v. State, 382 S.W.3d 377 (Tex. Crim. App. 2012) (intent to kill may be inferred from use of a deadly weapon)
- Adanandus v. State, 866 S.W.2d 210 (Tex. Crim. App. 1993) (use of a deadly weapon in a deadly manner strongly supports inference of intent to kill)
- Isassi v. State, 330 S.W.3d 633 (Tex. Crim. App. 2010) (standard for reviewing legal sufficiency and deference to jury credibility determinations)
- Oursbourn v. State, 259 S.W.3d 159 (Tex. Crim. App. 2008) (framework for voluntariness and Miranda/due‑process suppression claims)
- Umana v. State, 447 S.W.3d 346 (Tex. App.—Houston [14th Dist.] 2014) (video‑recorded statement may demonstrate voluntariness despite later findings of mental illness)