Braughton, Christopher Ernest
569 S.W.3d 592
| Tex. Crim. App. | 2018Background
- May 2013: Christopher Braughton shot and killed neighbor Emmanuel Dominguez after a car/motorcycle confrontation; Braughton admitted firing but claimed self-defense and defense of his father.
- Competing witness accounts: Braughton’s family testified Dominguez punched the father, threatened he had a gun, and reached into a motorcycle saddlebag; other witnesses (including a neighbor "Gina") described Dominguez backing away with hands raised and not reaching for a weapon.
- No weapon was recovered on Dominguez; medical examiner testified the bullet entered the right armpit area, consistent with either reaching or turning/backing up.
- Jury convicted Braughton of murder and rejected self-defense and defense-of-third-person instructions; sentenced to 20 years.
- Court of Appeals affirmed; Texas Court of Criminal Appeals granted review and ultimately affirmed the court of appeals: evidence was legally sufficient to reject the defensive theories and any omission of a felony-deadly-conduct instruction was harmless.
Issues
| Issue | Plaintiff's Argument (Braughton) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Sufficiency to reject self-defense/defense-of-third-person | Jury could not rationally disbelieve strong defensive testimony showing Dominguez threatened and reached for a gun | Credible conflicting evidence (witness Gina, measurements, lack of weapon) allowed jury to reject defensive claims | Evidence legally sufficient to support jury’s rejection of defenses; conviction affirmed |
| Applicability of presumption under Tex. Penal Code §9.32(b) | Presumption of reasonableness should have favored Braughton because he believed serious crime/robbery was imminent | Jury could rationally find Braughton lacked reason to believe robbery/murder was occurring | Court upheld that jury could rationally find presumption inapplicable; no reversible error |
| Omission of lesser-included felony deadly-conduct instruction | Failure to instruct deprived jury of intermediate verdict option and was harmful | Jury was instructed on manslaughter (intervening lesser offense) and rejected it; counsel argued self-defense, not lack of intent | Even if omission was error, it was harmless under Almanza; no prejudice shown |
| Standard for appellate sufficiency review of defensive issues | Appellate courts should not permit speculative/inconsistent weighing that discounts defense evidence | Apply Jackson/Brooks framework; defer to jury credibility determinations unless irrational | Court reiterated standard: view evidence in light most favorable to verdict and defer to jury; no error in court of appeals’ application |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes constitutional sufficiency standard for criminal convictions)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (reviewing sufficiency by deferring to jury credibility and viewing evidence in light most favorable to verdict)
- Saxton v. State, 804 S.W.2d 910 (Tex. Crim. App. 1991) (defendant bears production burden for self-defense; jury’s guilty verdict implicitly rejects self-defense)
- Zuliani v. State, 97 S.W.3d 589 (Tex. Crim. App. 2003) (clarifies burdens: production vs State’s persuasion to disprove defense)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (sufficiency review—reasonable inferences from evidence)
- Masterson v. State, 155 S.W.3d 167 (Tex. Crim. App. 2005) (failure to submit a lesser offense may be harmless when jury rejects intervening offense)
- Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (harm analysis for jury-charge error)
- Febus v. State, 542 S.W.3d 568 (Tex. Crim. App. 2018) (jury may accept parts of witness testimony and reject others)
- Adames v. State, 353 S.W.3d 854 (Tex. Crim. App. 2011) (defer to jury’s role as sole judge of credibility)
- Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (appellate courts must not substitute their judgment for the jury’s)