Derryck Jerod James v. State, 05-15-00176-CR

Appellant Derryck Jerod James was convicted by a jury of aggravated robbery with a deadly weapon and sentenced to 30 years' imprisonment.
Victim Jeany Turner, age 77, testified she was robbed at gunpoint outside her home; she later sold her house and moved in with family because of safety fears.
Police traced purchases made with Turner’s stolen credit cards; Marcus Davis and Jeremy Warren used the cards at multiple stores.
Davis pawned property bought with the stolen cards and implicated James; Davis testified James delivered the cards and admitted participation as the getaway/driver.
Detective Shelton videotaped James’s interrogation where James admitted driving accomplices to and from the scene and receiving stolen credit cards.
On appeal James raised two issues: (1) admission of the victim’s testimony about life changes (victim‑impact evidence) during guilt/innocence; and (2) failure to give an accomplice‑witness jury instruction regarding Marcus Davis.

Issue	Plaintiff's Argument (State)	Defendant's Argument (James)	Held
Admission of victim’s testimony about selling her home/moving	Testimony is relevant to prove victim’s fear supporting that a deadly weapon was used	Testimony was victim‑impact/punishment evidence and irrelevant at guilt/innocence	Any error was non‑constitutional and harmless given strong corroborating evidence (affirmed)
Failure to give accomplice‑witness instruction for Marcus Davis	Davis was not an accomplice to the aggravated robbery; no instruction required	Davis was an accomplice whose testimony required corroboration, and omission was error	Davis was not an accomplice as a matter of law; no instruction required (affirmed)

Tillman v. State, 354 S.W.3d 425 (Tex. Crim. App. 2011) (abuse‑of‑discretion review for evidentiary rulings)
Lane v. State, 822 S.W.2d 35 (Tex. Crim. App. 1991) (definition and limits of victim‑impact testimony)
Miller–El v. State, 782 S.W.2d 892 (Tex. Crim. App. 1990) (victim’s future hardship irrelevant to guilt phase)
Motilla v. State, 78 S.W.3d 352 (Tex. Crim. App. 2002) (standards for assessing harm from evidentiary error)
Johnson v. State, 967 S.W.2d 410 (Tex. Crim. App. 1998) (overturning non‑constitutional error only if substantial rights affected)
Druery v. State, 225 S.W.3d 491 (Tex. Crim. App. 2007) (when accomplice‑witness instruction is required)
Paredes v. State, 129 S.W.3d 530 (Tex. Crim. App. 2004) (post‑offense assistance does not make witness an accomplice)
Kunkle v. State, 771 S.W.2d 435 (Tex. Crim. App. 1986) (complicity in a separate offense does not make witness an accomplice to the charged offense)
Casanova v. State, 383 S.W.3d 530 (Tex. Crim. App. 2012) (standard for egregious harm when charge error not objected to)