Charles Roberts v. State, 14-14-00874-CR

Victim found shot once in his car outside a grocery store; no physical evidence or eyewitnesses.
Phone/text records tied appellant (Roberts) to arranging a marijuana sale and placed him near the scene; acquaintance alleged Roberts confessed in jail.
At trial Roberts admitted going to buy hydroponic marijuana but denied confessing; jury convicted him of murder and assessed 50 years’ imprisonment.
Before Roberts testified, the court held an outside-the-presence hearing about impeachable priors; the court admitted a misdemeanor assault conviction for impeachment.
During punishment Roberts testified in visible leg irons; defense did not object and did not move for new trial or provide affidavit explaining strategy.
The punishment evidence included unadjudicated jail-discipline incidents; the court omitted a sua sponte reasonable-doubt instruction for those bad acts and Roberts did not request one.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of misdemeanor assault as impeachment (moral turpitude under Tex. R. Evid. 609)	Roberts: assault is not a crime involving moral turpitude, so prior was inadmissible.	State: objection at trial was only "more prejudicial than probative," so appellate complaint not preserved.	Not preserved on appeal; objection at trial lacked the specific ground now asserted, so no reversal.
Ineffective assistance for failure to object to visible shackles during punishment	Roberts: counsel’s failure to object to shackles deprived him of effective assistance and was inherently prejudicial.	State: counsel may have chosen not to object as strategy (to elicit sympathy); no record explaining counsel’s tactics.	Strickland standard not met on silent record; presumption of reasonable strategy unrebutted, so claim fails.
Failure to give sua sponte reasonable-doubt instruction for unadjudicated bad acts during punishment	Roberts: omission was reversible error that egregiously harmed his punishment case.	State: omission was error but not egregiously harmful given the charge, evidence strength, and arguments.	Error acknowledged but harmless under Almanza standard — no egregious harm shown; conviction affirmed.

Strickland v. Washington, 466 U.S. 668 (ineffective-assistance two-prong test)
Holbrook v. Flynn, 475 U.S. 560 (shackles are inherently prejudicial when visible)
Deck v. Missouri, 544 U.S. 622 (due process limits visible shackling; special circumstances required)
Estelle v. Williams, 425 U.S. 501 (defense tactic of presenting defendant in jail clothing may be used to elicit sympathy)
Resendez v. State, 306 S.W.3d 308 (Tex. Crim. App.) (preservation requirement: timely, specific objections)
Huizar v. State, 12 S.W.3d 479 (Tex. Crim. App.) (reasonable-doubt instruction for unadjudicated offenses required)
Bluitt v. State, 137 S.W.3d 51 (Tex. Crim. App.) (no instruction required for prior offenses already adjudicated)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App.) (egregious-harm standard for unobjected-to charge error)
Stuhler v. State, 218 S.W.3d 706 (Tex. Crim. App.) (factors for assessing egregious harm)