Dante Coleman v. State
01-13-00255-CR
Tex. App.Jun 17, 2014Background
- Appellant Dante Coleman was convicted of burglary of a habitation in Harris County, Texas, based on evidence at trial that a burglary occurred at Resa Castillo’s home on December 2, 2009.
- Castillos left their home for work that morning; later that day a neighbor observed a man, identified as Coleman, near the back of the house and looking into a window.
- Dupuis testified she saw Coleman near the residence, then observed him run to a car, open the back door, and join the front passenger seat in a vehicle matching an earlier sighting.
- Castillo’s stepson found a broken window and tipped-over golf clubs; a DVD player and 17 movies were later found at a pawn shop with Coleman’s name on the pawn slip and his identification used.
- A pawn-shop clerk identified Coleman as the person who sold the items and testified he negotiated the sale; Dupuis identified Coleman from a photo array and at trial.
- The jury returned a guilty verdict; the trial court sentenced Coleman to 15 years in prison.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence proves entry of the habitation as charged | Coleman asserts the State failed to prove he entered the home. | State relied on look-alike or conspiratorial theories without direct entry proof. | Evidence was sufficient to prove entry by Coleman |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard: rational juror could find guilt beyond reasonable doubt)
- Byrd v. State, 336 S.W.3d 242 (Tex. Crim. App. 2011) (reaffirmation of Jackson standard for sufficiency review)
- Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (circumstantial evidence considered with direct evidence)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (clarifies sufficiency evaluation under Jackson)
- Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (principles for evaluating circumstantial evidence)
- Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (confirms deference to jury's factual resolutions)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (fact-finder credibility and inference sufficiency)
- Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (treats direct and circumstantial evidence equally)
