Eddie Ray Routh v. State
2017 Tex. App. LEXIS 2833
| Tex. App. | 2017Background
- Appellant Eddie Ray Routh, an ex-Marine with prior VA hospitalizations and diagnoses (PTSD, prior psychotic episodes), was convicted by a jury of capital murder for killing Chris Kyle and Chad Littlefield; the State did not seek death and trial court sentenced life without parole.
- Routh shot both victims multiple times at a shooting range, fled in Kyle’s pickup, was pursued and arrested; physical and forensic evidence tied recovered bullets to weapons and to the scene.
- The defense asserted an insanity affirmative defense under Tex. Penal Code § 8.01 (severe mental disease or defect such that defendant did not know conduct was wrong); Routh presented Dr. Mitchell Dunn (schizophrenia diagnosis). The State presented Drs. Randall Price and Michael Arambula (cannabis-induced psychosis or intoxication/mood disorder; Routh knew his conduct was wrong).
- Routh made post-arrest statements to Texas Ranger Danny Briley admitting the killings, describing delusional beliefs, and stating both that he knew killing was wrong and that he felt compelled for self-defense; police recorded and admitted the interview.
- Routh moved to suppress the Briley interview claiming he was psychotic and did not validly waive Miranda; he also moved for mistrial after the prosecutor displayed a lab vial not seized at the scene. Trial court denied suppression and denied mistrial; jury rejected insanity defense and convicted.
- The court of appeals (11th COA) reviewed three points: (1) sufficiency challenge to jury rejection of insanity defense, (2) denial of motion to suppress, and (3) denial of mistrial for vial display; the court affirmed.
Issues
| Issue | Appellant's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence rejecting insanity defense | Routh argued he suffered severe mental disease (schizophrenia) and did not know his conduct was wrong. | State argued evidence (forensics, Routh’s admissions, experts attributing symptoms to intoxication/drug-induced psychosis, flight, remorse) supported jury rejection. | Affirmed — more-than-scintilla and not so against weight of evidence; competing expert testimony created fact question for jury. |
| Suppression of custodial statement | Routh argued he was psychotic, did not understand or validly waive Miranda, and statement involuntary. | State argued Briley warned Routh, Routh nodded and talked coherently about details, did not ask for counsel; no coercion shown. | Affirmed — trial court’s factual findings supported; totality of circumstances showed voluntary, knowing waiver. |
| Mistrial for prosecutor displaying unadmitted vial | Routh argued display implied presence of illicit drugs and prejudiced jury; instruction insufficient. | State explained vial was a lab artifact, chemist testified, vial withdrawn, jury instructed to disregard. | Affirmed — court did not abuse discretion; curative instruction + chemist’s testimony dispelled prejudice. |
Key Cases Cited
- Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (defines “wrong” under insanity statute as “illegal” and explains inquiry into defendant’s factual knowledge of illegality)
- Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (standards for reviewing legal and factual sufficiency of rejection of affirmative defenses)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standards for legal-sufficiency review — more-than-scintilla and crediting favorable evidence)
- Meraz v. State, 785 S.W.2d 146 (Tex. Crim. App. 1990) (weight-of-the-evidence standard for factual sufficiency review)
- Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (bifurcated review of suppression rulings; deference to trial court findings)
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (deference to trial court on historical facts and credibility in suppression hearings)
- Joseph v. State, 309 S.W.3d 20 (Tex. Crim. App. 2010) (waiver of Miranda can be inferred from words and actions; explicit verbal waiver not required)
- Casias v. State, 452 S.W.2d 483 (Tex. Crim. App. 1970) (confession inadmissible if mental impairment prevents understanding meaning/effect of confession)
- Terrazas v. State, 4 S.W.3d 720 (Tex. Crim. App. 1999) (when defendant raises voluntariness, prosecution must prove voluntariness by preponderance)
- Gamboa v. State, 296 S.W.3d 574 (Tex. Crim. App. 2009) (mistrial standard; abuse of discretion review)
- Hawkins v. State, 135 S.W.3d 72 (Tex. Crim. App. 2004) (mistrial warranted only in extreme circumstances; jury instructions generally cure errors)