Deedra Michelle Grubbs v. State
12-14-00150-CR
| Tex. App. | Jul 21, 2015Background
- Deedra Grubbs is the appellant in a Shelby County murder prosecution; the State is the appellee.
- Co-defendant Bobbie Grubbs testified at appellant’s trial detailing her involvement and framing of events.
- Defense sought to admit letters from the co-defendant written from jail after the crimes, claiming declaration against penal interest and corroboration.
- The trial court excluded the letters as hearsay; defense did not timely offer them during witness testimony.
- The State objected to the letters on hearsay grounds; the court analyzed admissibility under Rule 803(24) and 801(e)(1)(B) with a six-factor corroboration test.
- The appellate analysis finds the exclusion proper under abuse-of-discretion standards, noting overwhelming evidence of guilt notwithstanding the exclusion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Issue A – Hearsay exclusion of co-defendant letters | Grubbs argues letters were admissible as declarations against penal interest or corroboration. | Grubbs contends letters should be admitted despite not being self-inculpatory or corroborated. | Exclusion affirmed; not self-inculpatory, untrustworthy, and not corroborated. |
| Issue B – Hearsay exclusion of co-defendant’s in-car video statements | Video statements should be admitted as declarations against penal interest or corroboration. | Video statements are admissible under the same theories as Issue A. | Exclusion affirmed for the same reasons as Issue A. |
Key Cases Cited
- Bigon v. State, 252 S.W.3d 360 (Tex. Crim. App. 2008) (abuse-of-discretion standard for evidentiary rulings; framework for Rule 803(24))
- Bingham v. State, 987 S.W.2d 54 (Tex. Crim. App. 1999) (two-step test for declaration against penal interest under 803(24))
- Dewberry v. State, 4 S.W.3d 735 (Tex. Crim. App. 1999) (six-part corroboration framework for statements against interest)
- Walter v. State, 267 S.W.3d 883 (Tex. Crim. App. 2008) (limits admissible self-inculpatory portions to those that are directly against penal interest)
- Coffin v. State, 885 S.W.2d 140 (Tex. Crim. App. 1994) (establishes standards for relevancy and error preservation in evidentiary rulings)
- Alford v. State, 400 S.W.3d 924 (Tex. Crim. App. 2013) (discusses abuse-of-discretion review and Rule 103/104 interaction)
- State v. Duran, 396 S.W.3d 563 (Tex. Crim. App. 2013) (harm analysis under TRAP 44.2(b) for non-constitutional error)
- Williamson v. U.S., 512 U.S. 594 (U.S. Supreme Court 1994) (context for corroboration and reliability of declarations against interest)