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