Daniel Lorenzo Wilson v. State, 03-15-00328-CR

Defendant Daniel Lorenzo Wilson pleaded guilty to murder; the trial court reserved punishment and later sentenced him to life imprisonment after a punishment hearing.
Eyewitness Latasha Brown (cohabitant/acquaintance) gave detailed, graphic testimony describing multiple shootings, blunt-force trauma with a flashlight, and dismemberment with a sword; she also recorded a 9-1-1 call identifying Wilson.
The State introduced numerous crime-scene photographs at punishment; appellant objected to seven particularly graphic, color images (blood/brain matter, bloody flashlight, sword, TV with brain matter), which were projected on a screen during the hearing.
Defense presented mitigating evidence: a psychologist testified Wilson has borderline IQ, possible schizophrenia/psychosis, and significant substance-abuse history; defense argued these factors warranted lesser punishment.
Appellant’s brief argues the challenged photographs were cumulative of Brown’s graphic testimony, unnecessary because guilt and injury were undisputed, and their prejudicial effect substantially outweighed probative value under Tex. R. Evid. 403.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of graphic crime-scene photographs at punishment	Wilson: photos were cumulative of Brown's vivid testimony, unnecessary given guilty plea, and their inflammatory nature substantially outweighed probative value under Rule 403	State: photos relevant to circumstances of the offense and extent of injuries; admissible for punishment-phase consideration	Trial court admitted the photographs; sentencing proceeded and life imprisonment assessed. Appellant seeks reversal on appeal for abuse of discretion in admitting the photos.
Harm from admission (standard of review and effect on substantial rights)	Wilson: erroneous admission was nonconstitutional error under Rule 44.2(b) and likely affected the trial judge’s punishment determination because images were gruesome, projected large, and appealed to emotion	State: relied on photos and other evidence (9-1-1 call, autopsy) to support punishment; probative value outweighed prejudice	Appellant urges appellate reversal and remand for new punishment hearing; the brief frames the error as having a substantial and injurious effect (grave doubt of harmlessness).

Erazo v. State, 144 S.W.3d 487 (Tex. Crim. App. 2004) (sets Rule 403 framework and Narvaiz factors for evaluating gruesome photographs at punishment)
Gallo v. State, 239 S.W.3d 757 (Tex. Crim. App. 2007) (abuse-of-discretion review for evidentiary rulings; relevance of photographs follows admissible testimony)
Narvaiz v. State, 840 S.W.2d 415 (Tex. Crim. App. 1992) (factors for assessing photographic evidence: number, size, color, gruesomeness, alteration by autopsy)
Reese v. State, 33 S.W.3d 238 (Tex. Crim. App. 2000) (weighing probative value vs. unfair prejudice of photographic evidence at punishment)
Miller-El v. State, 782 S.W.2d 892 (Tex. Crim. App. 1990) (extent of victim’s injuries admissible at punishment when tied to moral culpability)
Burnett v. State, 88 S.W.3d 633 (Tex. Crim. App. 2002) (harmless-error/grave-doubt discussion for nonconstitutional errors)