Clifford James Gayton, Jr. v. State, 06-16-00217-CR

On January 27, 2016, police responding to a 9‑1‑1 call found two‑year‑old David cold and not breathing; attempts to revive him failed.
Clifford James Gayton, Jr., who was caring for the children while their mother (Lucas) was at work, informed officers that one‑year‑old Mary was in a bedroom.
Officers found Mary awake but not responding normally and observed extensive bruising and discoloration on her chest, abdomen, face, genital area, and inner thighs.
Gayton gave varying and contradictory explanations for the children’s injuries and admitted the injuries occurred while the children were in his care; he also smoked synthetic marijuana multiple times that day.
Gayton was tried jointly for capital murder (David) and injury to a child (Mary); a jury convicted him of both. This appeal challenges only the legal sufficiency of the evidence as to the injury‑to‑a‑child conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether legally sufficient evidence proved Gayton intentionally or knowingly caused bodily injury to Mary under Tex. Penal Code § 22.04(a)(3)	The State: jury could infer intent/knowledge from the nature and extent of Mary’s injuries, similarity to David’s injuries, Gayton’s inconsistent explanations, his admission the injuries occurred while the children were in his care, his behavior (drug use, nervous pacing, lack of emotion), and disparity in size/strength	Gayton: evidence insufficient to prove he acted intentionally or knowingly to cause Mary’s injuries (challenges mental‑state proof)	Court affirmed: viewing evidence in the light most favorable to the verdict, a rational jury could infer Gayton intended or was aware his conduct was reasonably certain to cause Mary’s injuries; evidence legally sufficient

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for reviewing sufficiency; Brooks/Jackson framework)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (due‑process standard for sufficiency of evidence)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (jury may draw reasonable inferences from circumstantial evidence)
Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (hypothetically correct jury charge governs sufficiency review)
Duren v. State, 87 S.W.3d 719 (Tex. App.—Texarkana 2002) (factors from which jury may infer intent/knowledge)
Patrick v. State, 906 S.W.2d 481 (Tex. Crim. App. 1995) (mental‑state inferences from acts, injuries, method used)
Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (clarifying result‑of‑conduct offenses require mental state as to result)