Burdane Maurice Granger v. State, 584 S.W.3d 571

On August 1, 2017, Burdane Maurice Granger forcibly pulled Carrie Guerrero by the hair and put her in a headlock outside her mother’s home; the incident was captured on a neighbor’s security camera and witnesses intervened.
Granger was arrested and indicted for felony assault—family violence, with habitual-offender and enhancement allegations; a Kerrville jury convicted him and the trial court sentenced him to 40 years’ confinement.
At trial, Guerrero testified she and Granger had an "on and off" dating relationship and had previously lived together; Granger referred to her as his girlfriend to the arresting officer.
Neighbors and the security footage corroborated the assault and testified that Granger was frequently at the residence and appeared to be in a dating relationship with Guerrero.
On appeal Granger raised two issues: (1) the trial court erred by omitting the statutory definition of "dating relationship" from the jury charge, and (2) the evidence was legally insufficient to prove a dating relationship.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Omission of statutory definition of "dating relationship" from jury charge	State: omission was harmless; jury could apply common meaning and evidence was undisputed	Granger: omission confused jury and caused egregious harm because related definitions were included	Court: Error presumed but not egregious; no reversal because jury could use common meaning and record showed no actual harm
Sufficiency of evidence that Granger and Guerrero had a "dating relationship"	State: testimony (victim and neighbors) and defendant's own statements support a continuing romantic relationship	Granger: evidence was conclusory; record lacked detail on length, nature, frequency of interactions	Court: Evidence legally sufficient; cumulative testimony and defendant’s statements allowed reasonable inference of a dating relationship

Adames v. State, 353 S.W.3d 854 (Tex. Crim. App. 2011) (standard for reviewing sufficiency of the evidence)
Gear v. State, 340 S.W.3d 743 (Tex. Crim. App. 2011) (deference to jury on credibility)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (reasonable inferences from basic facts)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (any rational trier of fact standard)
Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (hypothetically correct jury charge framework)
Sanchez v. State, 499 S.W.3d 438 (Tex. Crim. App. 2016) (definition of dating relationship under Family Code)
Herrera v. State, 526 S.W.3d 800 (Tex. Crim. App. 2017) (three-factor test for dating relationship)
Villarreal v. State, 286 S.W.3d 321 (Tex. Crim. App. 2009) (dating relationship can have ended before assault)
Balderas v. State, 517 S.W.3d 756 (Tex. Crim. App. 2016) (deference to jury to resolve conflicts)
Villarreal v. State, 453 S.W.3d 429 (Tex. Crim. App. 2015) (Almanza standard for jury-charge harm)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1984) (harmless-error/egregious harm framework)
Olveda v. State, 650 S.W.2d 408 (Tex. Crim. App. 1983) (jury may apply commonly understood meanings when statutory definition omitted)