Deedra Michelle Grubbs v. State
12-14-00150-CR
| Tex. App. | Dec 30, 2015Background
- Deedra Michelle Grubbs was convicted by a jury of capital murder (one count) and two counts of aggravated assault arising from a home-invasion robbery and subsequent motel shootings; she received life without parole and two 20-year sentences.
- Appellant and her husband, Bobbie, went to a former employer’s home where Bobbie assaulted the owner; Appellant took guns and jewelry and left with him. Victim recovered and police searched for them.
- While fleeing, the couple stayed at a motel; Bobbie shot three motel employees to steal a vehicle, killing one. Both were arrested the day of the shootings.
- After arrest, Bobbie made multiple statements in a police car video and in jail letters confessing to the crimes and asserting that Appellant was innocent and had been coerced at gunpoint.
- Appellant sought to admit Bobbie’s police-video statements and letters under the hearsay exception for statements against penal interest (Tex. R. Evid. 803(24)); the trial court excluded them and Appellant appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Bobbie’s letters as statements against penal interest | Bobbie’s written confessions and exculpatory statements about Grubbs are against his penal interest and are corroborated, so admissible under Rule 803(24) | State: statements are hearsay and lack sufficient corroborating circumstances to show trustworthiness | Court: letters are against Bobbie’s interest but lack sufficient corroborating circumstances; exclusion affirmed |
| Admissibility of Bobbie’s in-car police video as statement against interest | Video confession is against penal interest and corroborates the letters; should be admitted | State: same hearsay objection; insufficient corroboration and potential motive to fabricate | Court: video contains statements against interest but fails Rule 803(24)’s corroboration requirement; exclusion affirmed |
Key Cases Cited
- Martin v. State, 173 S.W.3d 463 (Tex. Crim. App.) (standard of review for admission of evidence: abuse of discretion)
- Willover v. State, 70 S.W.3d 841 (Tex. Crim. App.) (appellate deference to trial court rulings on evidence)
- Burden v. State, 55 S.W.3d 608 (Tex. Crim. App.) (will not reverse evidentiary rulings within zone of reasonable disagreement)
- Taylor v. State, 268 S.W.3d 571 (Tex. Crim. App.) (proponent bears burden to show hearsay exception applies)
- Walter v. State, 267 S.W.3d 883 (Tex. Crim. App.) (requirements for statements against penal interest under Rule 803(24))
- Davis v. State, 872 S.W.2d 743 (Tex. Crim. App.) (focus of corroboration inquiry is trustworthiness to avoid fabrications)
- Cunningham v. State, 877 S.W.2d 310 (Tex. Crim. App.) (factors for evaluating corroborating circumstances and consideration of undermining evidence)