Corey Deshundon Henderson v. the State of Texas, 10-19-00365-CR

Appellant Corey Deshundon Henderson was convicted of continuous trafficking of persons (Tex. Penal Code §20A.03) and sentenced to 99 years.
The indictment alleged a 30+ day course of conduct from on or about March 1, 2017 through January 29, 2018, listing multiple predicate acts against two victims.
The jury charge’s abstract portion used a broad “on or about”/time-bar explanation that could be read to permit conviction for acts outside the indicted date range.
The application paragraph, however, expressly limited the jury to finding offenses during the indictment’s March 1, 2017–January 29, 2018 period.
Henderson did not object to the charge at trial and therefore had to show egregious harm on appeal; the Court examined the charge, the evidence, closing arguments, and the record as a whole.
The court assumed, without deciding, that the abstract portion contained error but held any error was not egregious because the application paragraph correctly limited the dates, the evidence supported conviction, and the State’s closing emphasized the indicted period and unanimity; the conviction was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury charge’s abstract language expanded criminal liability beyond the indictment dates and thereby egregiously harmed Henderson	The State argued the application paragraph correctly limited the jury to the indicted date range, so any abstract error was not harmful	Henderson argued the abstract instruction allowed conviction for conduct outside the indicted dates and, because he did not object, he suffered egregious harm depriving him of a fair trial	The court held any error in the abstract portion was not egregious because the application paragraph properly limited the dates, the evidence supported the verdict, and closing argument did not invite reliance on dates outside the indictment; conviction affirmed

Hutch v. State, 922 S.W.2d 166 (Tex. Crim. App. 1996) (first step: determine whether jury‑charge error exists)
Middleton v. State, 125 S.W.3d 450 (Tex. Crim. App. 2003) (if error exists, analyze harm)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (preservation rule and egregious‑harm standard for unobjected errors)
Sanchez v. State, 376 S.W.3d 767 (Tex. Crim. App. 2012) (reversal requires actual, not theoretical, harm)
Arline v. State, 721 S.W.2d 348 (Tex. Crim. App. 1986) (harm requirement for charge errors)
Olivas v. State, 202 S.W.3d 137 (Tex. Crim. App. 2006) (factors to evaluate egregious harm: charge, evidence, arguments, whole record)
Stuhler v. State, 218 S.W.3d 706 (Tex. Crim. App. 2007) (egregious harm affects the case’s very basis, a valuable right, or a defensive theory)
Medina v. State, 7 S.W.3d 633 (Tex. Crim. App. 1999) (application paragraph that correctly limits the law mitigates abstract errors)
Plata v. State, 926 S.W.2d 300 (Tex. Crim. App. 1996) (superfluous abstract language does not produce reversible error when application restricts jury)
Grady v. State, 614 S.W.2d 830 (Tex. Crim. App. 1981) (same principle regarding abstract vs. application paragraphs)
Kuhn v. State, 393 S.W.3d 519 (Tex. App.—Austin 2013) (reinforcing that a correct application paragraph weighs against finding abstract error egregious)