Edwards, Keith Wayne
PD-0224-15
| Tex. App. | Apr 22, 2015Background
- Defendant Keith Wayne Edwards was indicted for murder after stabbing Samuel Anderson with a piece of broken glass on a DART train; Anderson later died from severed carotid arteries.
- Event sequence: verbal/physical altercation on the train between Edwards, Anderson, and Ramirez; Edwards swung a bag, exited train, attempted to reboard, and jabbed Anderson through the train door.
- Recording(s) from a passenger and platform video were admitted; recordings show portions of the confrontation but do not capture every moment.
- Edwards testified Anderson displayed a small-caliber pistol, threatened to shoot him, kicked and called him names, and Edwards jabbed because he feared being shot; Edwards also admitted provocation and anger.
- The jury convicted Edwards of the lesser-included offense of manslaughter (recklessness) and sentenced him to 11 years; Edwards appealed claiming evidence was legally insufficient because his self-defense claim could not reasonably be rejected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was legally sufficient to support manslaughter conviction given Edwards's claim of self-defense | Edwards: No rational juror could reject his self-defense testimony; evidence conclusively supports justification | State: Viewed in the light most favorable to the verdict, a rational juror could disbelieve Edwards, find recklessness, and reject self-defense | Court affirmed: a rational jury could find all elements of manslaughter and discredit self-defense beyond a reasonable doubt |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for legal sufficiency review)
- Saxton v. State, 804 S.W.2d 910 (Tex. Crim. App. 1991) (sufficiency review when self-defense asserted)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson standard is controlling)
- Montgomery v. State, 369 S.W.3d 188 (Tex. Crim. App. 2012) (appellate duty to ensure evidence supports verdict)
- Chambers v. State, 805 S.W.2d 459 (Tex. Crim. App. 1991) (factfinder determines credibility)
- Wise v. State, 364 S.W.3d 900 (Tex. Crim. App. 2012) (deference to jury on credibility)
