Candra Nicole Applegate v. State, 11-14-00005-CR

Appellant Candra Applegate was tried for four offenses: two counts of serious bodily injury to a child (first-degree felonies) and two counts of bodily injury to a child (third-degree felonies) relating to fractures to her nine‑month‑old twins, T.L.W. and W.L.W.
Medical evidence (skeletal surveys and radiology) showed multiple fractures (including ‘‘corner fractures’’) of varying ages in both twins; experts testified the injuries were highly specific for abuse and required tremendous force.
Appellant was primarily the twins’ caregiver; other witnesses said Daniel Wright (father) was rarely alone with the children and Appellant often had bruised infants and avoided public outings because CPS had been called.
The State prosecuted Appellant as the person who intentionally or knowingly caused the injuries (one count alleged omission for failing to obtain medical care).
The jury convicted on all four counts; the trial court imposed concurrent sentences (ten years for each bodily‑injury count, twenty‑six years for each serious‑bodily‑injury count).

Issue	Appellant's Argument	State's Argument	Held
Sufficiency—identity/causation	Evidence only shows Appellant, Daniel, or both could have caused injuries; conviction on Appellant alone irrational without party instruction	Medical and circumstantial evidence (force, timing, Appellant alone with children) supports jury inference Appellant caused injuries	Affirmed: evidence sufficient for convictions
Sufficiency—failure to provide medical care	Appellant could not reasonably know T.L.W. needed care because X‑rays revealed fractures	Medical testimony and observable deformity showed Appellant knew or should have known and delay aggravated injury	Affirmed: omission caused serious bodily injury
Sufficiency—"manner and means unknown" element	Grand jury’s ‘‘manner and means unknown’’ required a grand juror to testify to preserve that element	Evidence showed manner of fracture not medically certain; ‘‘unknown’’ satisfied without grand juror testimony	Affirmed: manner and means could remain unknown to grand jury; no grand juror testimony required
Alleged improper judicial comments	Trial judge’s reference to common/"boilerplate" jury instructions de‑emphasized Appellant’s rights and was fundamentally harmful	No objection was made at trial; judge repeated that rights remained important and fully instructed jury; any error waived	Affirmed: complaint waived for failure to object; no reversible error

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
Brooks v. State, 323 S.W.3d 893 (Texas standard for reviewing sufficiency under Jackson)
Guevara v. State, 152 S.W.3d 45 (circumstantial evidence—combined force of evidence may sustain conviction)
Unkart v. State, 400 S.W.3d 94 (preservation of error rules for trial objections and mistrial requests)
Sanchez v. State, 376 S.W.3d 767 (limits on ‘‘manner and means unknown’’ allegations and jury instruction issues)
Malik v. State, 953 S.W.2d 234 (distinguishing instruction issues from evidentiary sufficiency)
Morales v. State, 828 S.W.2d 261 (medical testimony that significant force was used may support intent to cause serious bodily injury)