Dennis Mike Cranfill v. State
03-16-00649-CR
| Tex. App. | Jul 14, 2017Background
- Deputies executed an outstanding arrest warrant at Dennis Cranfill’s residence; a gated corridor prevented immediate entry.
- Officers heard a loud scream; they found Shannon Maddux inside the gated corridor, hysterical, limping, and requesting help.
- After cutting the gate chains, officers observed abrasions on Maddux’s neck and thigh and blood in her mouth; Cranfill was arrested at the scene.
- Maddux testified Cranfill assaulted her with a steel cable, choked and bit her, loosened a tooth, and fractured her foot; she used a cast and crutches and was impaired for roughly six weeks to two months.
- Photographs, officer observations, and a Texas Ranger’s interview corroborated visible injuries and post-assault impairment.
- Cranfill was convicted by a jury of kidnapping and aggravated assault causing serious bodily injury and sentenced to concurrent 70-year terms; he appealed, arguing insufficient evidence of serious bodily injury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence sufficed to prove Cranfill caused "serious bodily injury" | Maddux/State: injuries (fractured foot, bruising, impaired mobility for weeks) constituted protracted loss or impairment and thus serious bodily injury | Cranfill: injuries were not protracted or life-threatening and therefore not "serious bodily injury" | Court affirmed: evidence (fracture, cast/crutches, continuing impairment, photos, officer observations) was sufficient to show protracted loss or impairment and meet the statutory definition |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard of review for sufficiency of the evidence)
- Murray v. State, 457 S.W.3d 446 (Tex. Crim. App. 2015) (applies Jackson standard in Texas and emphasizes viewing evidence in light most favorable to verdict)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (on reasonable inferences from evidence)
- Blea v. State, 483 S.W.3d 29 (Tex. Crim. App. 2016) (serious bodily injury assessment excludes effects of medical treatment)
- Brown v. State, 605 S.W.2d 572 (Tex. Crim. App. 1980) (examples of injuries qualifying as serious bodily injury)
- Jenkins v. State, 493 S.W.3d 583 (Tex. Crim. App. 2016) (circumstantial evidence can be as probative as direct evidence)