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Christopher O. Woodruff v. State
04-10-00078-CR
Tex. App.
Oct 27, 2010
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Background

  • 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)
Read the full case

Case Details

Case Name: Christopher O. Woodruff v. State
Court Name: Court of Appeals of Texas
Date Published: Oct 27, 2010
Docket Number: 04-10-00078-CR
Court Abbreviation: Tex. App.