Chase Karrenbrock v. State, 02-16-00386-CR

Background

Appellant Chase Karrenbrock (age 21) was convicted by a jury of burglary of a habitation with intent to commit aggravated robbery; no one was physically injured and no property was taken. It was his first felony.
At sentencing the judge (after Karrenbrock elected judicial sentencing) assessed punishment at 60 years imprisonment.
The State introduced testimony about an unadjudicated hotel altercation in which Karrenbrock sustained injuries; the prosecutor argued it was an extraneous violent act. Karrenbrock denied striking anyone; no charges were shown filed.
The trial judge stated he would have imposed 20–30 years on the burglary alone, but increased the sentence by 30–40 years based largely on the hotel incident and denied a new-trial motion challenging disproportionality.
Appellant appealed, arguing the 60-year sentence is grossly disproportionate (Eighth Amendment), the judge improperly relied on the unproven extraneous incident (due process/Apprendi-type concerns), and the court abused discretion by failing to apply the modified Solem disproportionality test.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether a 60‑year sentence for a first non‑injury felony violates the Eighth Amendment (gross disproportionality).	Karrenbrock: sentence is grossly disproportionate given youth, lack of prior felonies, no injury, and comparative sentencing norms.	State: (implicit) judge permissibly considered offense gravity and extraneous conduct when setting punishment.	Trial court imposed 60 years; denied new‑trial relief. Appellant seeks reversal for Eighth Amendment violation.
2. Whether the trial court abused discretion by focusing almost exclusively on the hotel incident instead of applying the modified Solem factors.	Karrenbrock: judge ignored majority of Solem factors and evidence showing his sentence far exceeds local and national norms.	State: (implicit) judge acted within discretion to weigh relevant conduct in sentencing.	Trial court relied mainly on hotel incident and declined to reduce sentence; appellant argues this was an abuse of discretion.
3. Whether the court erred in admitting/considering the unadjudicated extraneous incident in punishment without proof beyond a reasonable doubt.	Karrenbrock: evidence did not establish he committed the assault beyond a reasonable doubt; he was more likely the victim; therefore use in sentencing violated due process.	State: (implicit) the judge could consider extraneous acts at punishment.	Trial court considered the incident and increased sentence; new‑trial motion denied. Appellant contends this violated due process.
4. Whether increasing sentence by 30–40 years based on an unproven misdemeanor (at most) is constitutionally impermissible.	Karrenbrock: even if the hotel event were an offense, it was at most a Class A misdemeanor (1 year max); tripling the sentence on that basis is unjustified and unconstitutional.	State: (implicit) judge's aggregate assessment justified the overall sentence.	Trial court explicitly stated it added decades based on the hotel incident; appellant claims this is prejudicial and warrants resentencing.

Key Cases Cited

Solem v. Helm, 463 U.S. 277 (U.S. 1983) (three‑factor disproportionality test comparing offense gravity, in‑jurisdiction sentences, and sentences in other jurisdictions)
Harmelin v. Michigan, 501 U.S. 957 (U.S. 1991) (Kennedy concurrence proposing a disproportionality “gateway” inquiry before full Solem comparison)
State v. Simpson, 488 S.W.3d 318 (Tex. Crim. App. 2016) (Texas adoption of the modified Solem framework)
McGruder v. Puckett, 954 F.2d 313 (5th Cir. 1992) (applying disproportionality analysis in the Fifth Circuit)
Rummel v. Estelle, 445 U.S. 263 (U.S. 1980) (upholding harsh sentence for recidivist nonviolent felonies; recidivism context contrasted with this case)
Graham v. Florida, 560 U.S. 48 (U.S. 2010) (Eighth Amendment proportionality principles cited)
Enmund v. Florida, 458 U.S. 782 (U.S. 1982) (individual culpability relevant to proportionality analysis)
Glover v. United States, 531 U.S. 198 (U.S. 2001) (any extra jail time can be prejudicial in sentencing context)
Jackson v. State, 680 S.W.2d 809 (Tex. Crim. App. 1984) (trial‑court abuse of discretion in sentencing when required standards not applied)