Carrizales v. State
2013 Tex. Crim. App. LEXIS 1809
| Tex. Crim. App. | 2013Background
- Appellant Arnold Carrizales was convicted after a bench trial for misdemeanor criminal mischief for placing metal roofing screws/nails on a county road that caused repeated flat tires to his neighbors, the Gomezes.
- The Gomezes and a deputy all experienced flats caused by the same distinctive roofing screws over months; the only traffic on the road were residents and oil trucks with no apparent reason to carry such screws.
- Carrizales admitted prior conduct of placing tree stumps in the road to slow the Gomezes and denied throwing screws, claiming they got there accidentally.
- The court of appeals held the evidence established both corpus delicti and Carrizales’s identity as the offender; Carrizales appealed the corpus delicti holding.
- The Court of Criminal Appeals granted review to clarify the scope of the common-law corpus-delicti rule post-Jackson v. Virginia and to assess sufficiency of the circumstantial evidence under Jackson.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Carrizales) | Held |
|---|---|---|---|
| Whether the common-law corpus delicti rule applies in non-confession cases after Jackson | Corpus delicti doctrine is unnecessary here; Jackson sufficiency review subsumes any corpus-delicti inquiry | Corpus delicti remains a distinct requirement and the proof was insufficient to show the damage resulted from criminality | Corpus delicti rule applies only as a special corroboration rule for extrajudicial confessions; in non-confession cases apply Jackson sufficiency standard |
| Whether evidence proved the elements of criminal mischief beyond a reasonable doubt (intent/causation) | Circumstantial evidence (repeated identical screws, prior obstruction conduct, limited other traffic) permits a rational factfinder to infer intentional placement | Repeated flats could be accidental or due to other sources (e.g., trucks); no direct proof someone intentionally placed screws | Under Jackson, circumstantial evidence was sufficient to prove intent and causation beyond a reasonable doubt; conviction affirmed |
| Whether identity and intent were impermissibly conflated by the court of appeals | The State may rely on the logical force of all circumstantial evidence, including prior acts, to prove each element | Court of appeals wrongly used identity evidence to satisfy corpus delicti and conflated issues | The court may consider all circumstantial evidence (including prior obstruction) to infer intent; resolving conflicts of testimony is the factfinder’s role |
| Whether repeated, similar accidents can be treated as coincidental (doctrine of chances) | Repeated uncommon events with the same unusual instrument support inference of intentional conduct | Repetition could still be coincidence without direct proof of who placed screws | The doctrine of chances supports inferring deliberate acts from repeated, highly unlikely events; accident inference rejected |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (establishes due-process legal-sufficiency standard for criminal convictions)
- De La Paz v. State, 279 S.W.3d 336 (Tex. Crim. App. 2009) (discusses "once is happenstance; twice is coincidence; third time it's enemy action" doctrine of chances)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence may be as probative as direct evidence)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson is sole standard for sufficiency review)
- Drager v. State, 548 S.W.2d 890 (Tex. Crim. App. 1977) (prior similar acts admissible to rebut accident defense and support intent)