Christopher O. Woodruff v. State
04-10-00078-CR
Tex. App.Oct 27, 2010Background
- Woodruff challenges the sufficiency of the evidence that he recklessly injured his 73-year-old father.
- He was charged with recklessly causing injury to an elderly individual by pushing his father out a door.
- The State presented the father's testimony and Woodruff's account of events to prove the act and its consequences.
- The trial court applied Jackson v. Virginia legal sufficiency review and the recklessness standard for a result offense.
- The court concluded the evidence was legally sufficient to support the conviction and affirmed the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there legally sufficient evidence of recklessly causing injury? | Woodruff argues the evidence fails to show recklessness. | Woodruff contends the State did not prove the required mental state. | Yes; evidence supports recklessness. |
Key Cases Cited
- Cano v. State, 614 S.W.2d 578 (Tex. Crim. App. 1981) (sufficient to support knowing or intentional bodily injury)
- Candaleria v. State, 776 S.W.2d 741 (Tex. App.—Corpus Christi 1989, pet. ref’d) (sufficient to establish intentional or knowing injury)
- Lane v. State, 763 S.W.2d 785 (Tex. Crim. App. 1989) (establishment of culpable mental states drawn from circumstances)
- Kelly v. State, 748 S.W.2d 236 (Tex. Crim. App. 1988) (culpable mental state for injury offenses; awareness and disregard)
- Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (recklessness analysis factors for result crimes)
