Christopher Ernest Braughton v. State
522 S.W.3d 714
| Tex. App. | 2017Background
- On May 24, 2013, Christopher Braughton (age 21) left his parents’ house with a 9mm handgun during a street altercation between Emmanuel Dominguez (decedent) and Braughton’s father; Braughton shot Dominguez once, killing him.
- Prior events: Dominguez (intoxicated) followed the Braughton family home on a motorcycle and engaged in a verbal and then physical altercation with Braughton Sr.; Braughton Sr. sustained a cut/bloody lip.
- Witness accounts conflicted on whether Dominguez threatened or reached for a weapon; no gun or weapon was recovered on Dominguez or in his saddlebags, though one saddlebag was open.
- Physical evidence: bullet entered under Dominguez’s right armpit and traversed to the left chest; medical testimony allowed that the wound could be consistent with Dominguez bending or reaching.
- Procedural posture: jury convicted Christopher of murder and assessed 20 years’ confinement; on appeal he challenged (1) sufficiency of evidence as to mens rea, (2) sufficiency to disprove his self-defense/defense-of-others claims, and (3) the trial court’s refusal to instruct on felony deadly conduct as a lesser-included offense.
Issues
| Issue | State's Argument | Braughton's Argument | Held |
|---|---|---|---|
| 1. Sufficiency of evidence of mens rea for murder | Evidence (viewed in prosecution’s favor) supports inference of intent/knowledge from purposeful use of a deadly weapon at close range and Chris’s own admissions. | Chris claimed he only intended to stop/scare Dominguez and pointed/shot without intent to kill; cooperation after shooting undermines intent inference. | Affirmed: a rational jury could infer intent/knowledge from the use of a firearm and surrounding facts. |
| 2. Sufficiency to disprove self-defense and defense of others | Jury reasonably discounted defensive testimony (conflicting witness accounts, lack of weapon on victim, non-deadly injuries to father, mother told Chris to put gun down), so State met burden to disprove defense beyond a reasonable doubt. | Chris produced evidence that he acted to protect his father after a phone call and that Dominguez said he had a gun and reached toward a saddlebag. | Affirmed: evidence raised defenses but jury could rationally reject them; conviction supported. |
| 3. Charge error: refusal to instruct on felony deadly conduct as lesser-included offense | Deadly conduct is a lesser-included offense but omission was harmless because the jury was instructed on manslaughter (an intervening lesser offense) and rejected it. | Chris argued the jury could have convicted only of deadly conduct (shot "towards" arm, not intending to kill). | Affirmed: even if instruction warranted, omission harmless because jury rejected manslaughter and manslaughter was at least as plausible. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
- Jones v. State, 944 S.W.2d 642 (intent may be inferred from use of deadly weapon)
- Bullock v. State, 509 S.W.3d 921 (two-prong test for lesser-included offense instruction)
- Cavazos v. State, 382 S.W.3d 377 (lesser-included offense standards)
- Saxton v. State, 804 S.W.2d 910 (State must disprove raised defenses beyond a reasonable doubt)
- Masterson v. State, 155 S.W.3d 167 (omission of lesser-included instruction may be harmless where intervening lesser was rejected)