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David Lee Seaton v. State
2012 Tex. App. LEXIS 6775
Tex. App.
2012
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Background

  • Seaton was convicted of manslaughter and aggravated assault by a public servant, with concurrent 15‑year and 10‑year sentences.
  • The victim Officer Robert Davis died after Seaton's patrol car collided with another vehicle in San Antonio.
  • Lampkin, the other motorist, was injured and had entered the intersection during a red signal.
  • Seaton was en route to a shoplifting call, speeding over 100 mph, without activating lights or siren.
  • Evidence showed red light at impact, no braking, and speeds over 90–100 mph; witnesses corroborated reckless driving.
  • Seaton challenged (1) charged status under color of office, (2) sufficiency of evidence, (3) jury misconduct ruling; all issues were upheld by affirmance.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Aggravated Assault by Public Servant was proper Seaton contends not acting under color. State argues Seaton acted under color of office. No error; Seaton acted under color.
Legal sufficiency of manslaughter and aggravated assault Lampkin credibility undermines proof beyond reasonable doubt. Evidence, including speeds and red light, supports guilt. Evidence legally sufficient; rational jury could convict.
Trial court ruling on jury misconduct motion Juror affidavits showed outside influence and misconduct. Exclusions proper; no outside influence established. Ruling not an abuse of discretion; error harmless; motion denied.

Key Cases Cited

  • Tapps v. State, 294 S.W.3d 175 (Tex. Crim. App. 2009) (statutory interpretation de novo)
  • Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (credibility and weight resolved by jury)
  • Easly v. State, 163 S.W.3d 839 (Tex. App.—Dallas 2005) (outside influence evidence restricted)
  • Fenoglio v. State, 252 S.W.3d 468 (Tex. App.—Fort Worth 2008) (outside information suppression in deliberations)
  • Rosell v. Cent. W. Motor Stages, Inc., 89 S.W.3d 643 (Tex. App.—Dallas 2002) (bailiff comment not outside influence)
Read the full case

Case Details

Case Name: David Lee Seaton v. State
Court Name: Court of Appeals of Texas
Date Published: Aug 15, 2012
Citation: 2012 Tex. App. LEXIS 6775
Docket Number: 04-11-00151-CR, 04-11-00152-CR
Court Abbreviation: Tex. App.