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Edwards, Keith Wayne
PD-0224-15
| Tex. App. | Apr 22, 2015
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Background

  • 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)
Read the full case

Case Details

Case Name: Edwards, Keith Wayne
Court Name: Court of Appeals of Texas
Date Published: Apr 22, 2015
Docket Number: PD-0224-15
Court Abbreviation: Tex. App.