Chad Michael Musgrove v. State
422 S.W.3d 13
Tex. App.2013Background
- Musgrove was convicted of capital murder and sentenced to life in prison under Tex. Pen. Code Ann. § 19.03.
- Before trial, a separate competency hearing determined Musgrove was not incompetent to stand trial; the appeal contests only this competency ruling.
- The jury did not find him incompetent; the appeal does not revisit the capital-trial merits.
- The trial record included Dr. Carter’s evaluation (approx. four hours) diagnosing competence, noting normal cognitive abilities (IQ 105) despite some delusional beliefs.
- Musgrove’s own expert, Dr. Mark, offered less definitive findings; the court weighed expert opinions on the six statutory competency factors.
- The court applied article 46B.003(a) and related provisions and conducted both legal and factual sufficiency reviews of the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal sufficiency of the evidence supporting the competency verdict | Musgrove argues the record shows incomptency as a matter of law | Musgrove contends the evidence supports incompetency; the jury erred | Evidence supports the jury’s refusal; legal-sufficiency upheld |
| Factual sufficiency of the evidence supporting the competency verdict | Musgrove contends the delusions and evidence favor incompetency, weight of evidence is strong | State argues the jury could credit expert opinions supporting competence | Verdict not against the great weight of the evidence; factual-sufficiency rejected |
Key Cases Cited
- Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (modified Sterner review for competency refusals; weigh evidence for sufficiency)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (establishes standard for reviewing sufficiency on mixed questions)
- Sterner v. Marathon Oil Co., 767 S.W.2d 686 (Tex. 1989) (standard framework for sufficiency review)
- Ex parte Lahood, 401 S.W.3d 45 (Tex. Crim. App. 2013) (factors to evaluate competency; supports using multiple indicators)
- Morris v. State, 301 S.W.3d 281 (Tex. Crim. App. 2009) (relates to competency standard and evidence evaluation)
- Nunez v. State, 942 S.W.2d 57 (Tex. App.—Corpus Christi 1997) (distinguishes cases where unanimous incompetency is shown)
- Aragon v. State, 910 S.W.2d 635 (Tex. App.—Beaumont 1995) (distinguishes cases with defendant testimony on competency)