Colette Reyes v. State
480 S.W.3d 70
| Tex. App. | 2015Background
- Colette Reyes was convicted by a jury of murder and sentenced to 45 years’ imprisonment for shooting and killing her husband; she admitted to police that she shot him and attempted to collect his $250,000 life insurance benefit afterward.
- Facts relevant to motive: husband moved out and intended to file for divorce; Reyes was the insurance beneficiary and expressed financial anxiety.
- Evidence of mental-health issues: prior diagnoses (paranoid schizophrenia / schizoaffective disorder), bizarre jail behavior, and expert testimony from Dr. Emily Fallis diagnosing schizoaffective disorder but unable to say Reyes did not know her conduct was wrong.
- State evidence: forensic psychologist Dr. Jack R. Price reviewed records and the audiotape and concluded Reyes did not suffer a severe mental disease or defect at the time and knew her conduct was wrong.
- A key piece of evidence was an audiotape of the event in which Reyes is recorded; both experts used the tape in forming opinions.
- Reyes raised four appellate points: (1) jury’s rejection of insanity defense was against the great weight of the evidence, (2) legal insufficiency for mens rea, (3) trial court erred by admitting the audiotape (chain of custody / Rule 403), and (4) prosecutor commented on her failure to testify, requiring mistrial.
Issues
| Issue | Plaintiff's Argument (Reyes) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1) Factual sufficiency of jury rejection of insanity affirmative defense | Reyes proved by preponderance she didn’t know conduct was wrong due to severe mental disease | Evidence conflicted; jury entitled to weigh credibility; State presented expert saying she was sane at time of offense | Court affirmed: jury verdict not against great weight; rejection of insanity was supported by record |
| 2) Sufficiency of evidence of mens rea for murder | Reyes lacked mental capacity/intent to form required mens rea | Circumstantial evidence (concealing guns, shooting at close range, insurance beneficiary, attempt to collect) supports intent/knowledge | Court affirmed: evidence sufficient for rational factfinder to find intent/knowledge beyond reasonable doubt |
| 3) Admission of audiotape (chain of custody / Rule 403) | Tape admission improper: chain of custody not shown; prejudicial under Rule 403 | Tape highly probative of manner, mental state; experts relied on it; court performed implicit Rule 403 balancing | Court affirmed: chain-of-custody objection not preserved; Rule 403 balancing within court’s discretion and tape admissible |
| 4) Prosecutor’s comment on defendant’s failure to testify / mistrial | Prosecutor’s remark during closing improperly commented on Reyes’s silence and required mistrial | Remarks were response to Reyes’s trial outbursts, not a comment on silence; prosecutor may comment on such evidence | Court affirmed: remark was permissible reaction to outbursts; mistrial denied |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (constitutional sufficiency standard for proving elements beyond a reasonable doubt)
- Matlock v. State, 392 S.W.3d 662 (standard for appellate review of affirmative defenses proved by preponderance)
- Butcher v. State, 454 S.W.3d 13 (legal vs. factual sufficiency challenges to affirmative defenses)
- Ruffin v. State, 270 S.W.3d 586 (insanity test: defendant did not know conduct was wrong due to severe mental disease or defect)
- Lantrip v. State, 336 S.W.3d 343 (deference to factfinder on conflicting insanity evidence)
- Mozon v. State, 991 S.W.2d 841 (Rule 403 balancing and unfair prejudice standard)
- Mechler v. State, 153 S.W.3d 435 (abuse-of-discretion review for Rule 403 rulings)
- Long v. State, 823 S.W.2d 259 (probative value of recordings of the offense)
- Johnson v. State, 583 S.W.2d 399 (prosecutor may comment on trial outbursts as evidence)