Dusti Kenne Lee v. State, 415 S.W.3d 915

Dusti Kenne Lee admitted shooting and killing Reggie Williams.
Trial judge oriented toward self-defense as a central issue; jury convicted Lee of murder and sentenced her to 75 years.
Lee requested a self-defense jury instruction tracking Section 9.32, including the State’s burden of persuasion; the trial court gave an erroneous charge.
The submitted charge would have placed a presumption of reasonableness on Lee’s belief if Williams met certain conditions; the actual charge misstated the State’s burden.
Evidence conflicted: some witnesses supported self-defense; others testified Lee distributed drugs and acted without justification.
Court held the error was present but not Harmful; affirming the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the jury charge erroneous regarding self-defense?	Lee argued presumption of reasonableness was mis-stated.	State claimed error but the charge largely tracked the law and constitutional burdens.	Yes, erroneous, but not harmful.
Was the jury-charge error preserved for appeal?	Lee preserved error through proposed charges and objections.	State argued error not properly preserved.	Error preserved.
Did the jury-charge error require reversal under Almanza/Abdnor standards?	Error affected the State’s burden and could mislead jurors.	No egregious harm; charge, viewed as a whole, did not injure Lee’s rights.	No reversible harm; not harmful.

Abdnor v. State, 871 S.W.2d 726 (Tex. Crim. App. 1994) (two-step harm analysis for jury-charge errors)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1984) (establishes harm framework for Almanza review)
Ngo v. State, 175 S.W.3d 738 (Tex. Crim. App. 2005) (egregious-harm standard when no objection)
Zuliani v. State, 97 S.W.3d 589 (Tex. Crim. App. 2003) (self-defense burden of persuasion; not an affirmative defense)
Kihega v. State, 392 S.W.3d 828 (Tex. App.—Texarkana 2013) (in assessing harm, consider entire trial record)