Erich Stockley Seals v. State, 09-15-00191-CR

Background

Seals was convicted by a jury of aggravated assault with a deadly weapon for shooting Donald Williams on April 30, 2013; the trial court assessed 25 years after a punishment hearing.
The State introduced Seals’s written statement and a police-recorded reenactment/video in which Seals described shooting through his partially open car window, and the gun was seized from his car with his consent.
Seals testified he acted in self-defense, claiming Williams approached, punched at his car window, and he shot to get Williams off him.
The State introduced evidence of a separate May 22, 2013 incident (video and testimony) showing Seals confronting Williams at a convenience store; the trial court admitted it to rebut Seals’s claim that he tried to avoid confrontations.
Seals raised multiple trial objections: ineffective assistance for counsel’s failure to obtain the May video earlier; Rule 404(b)/403 challenges to the May-incident evidence; challenges to limiting instructions and self-defense jury charge; Crawford/Miranda/hearsay objections to his statements and reenactment video; and sufficiency of proof for a 1994 prior conviction used for enhancement.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Seals)	Held
1. Ineffective assistance of counsel for failing to obtain/view May-incident video pretrial	Counsel had opportunity and the missing video was not the defense’s fault; no showing that lack of earlier review undermined reliability of trial outcome	Counsel failed to investigate and review video; prejudice would likely change result	Rejected – record silent on counsel’s strategy; appellant failed to prove deficient performance or prejudice under Strickland
2. Admissibility of May incident under Tex. R. Evid. 404(b)	Evidence was admissible to rebut Seals’s self-defense theory and show motive/plan given proximity and similarities	Evidence was improper character-conformity evidence	Admissible – trial court reasonably found non-propensity relevance (rebuttal of self-defense); within zone of reasonable disagreement
3. Admission of May incident under Rule 403 (prejudice vs probative value)	Probative to rebut defense; limiting instruction given; probative outweighs prejudice	Highly prejudicial, confused issues, not necessary	Rejected – court presumed to have balanced under Rule 403; any error harmless given other evidence that undermined self-defense
4. Limiting instruction and jury charge on extraneous-offense use	Limiting instruction and written charge explained the defensive theory and restricted use to rebuttal	Limiting instruction was insufficient and charge failed to identify the defense theory for which evidence was admitted	No reversible error – instruction and charge properly tied extraneous evidence to defendant’s self-defense/aggressor claim; Owens distinguished because self-defense was explicit here
5. Self-defense jury charge (request to tell jurors to put themselves in defendant’s shoes)	Statutory language adequately instructs jury; non-statutory instruction not required	Jury should be told to view circumstances from defendant’s perspective	Denied – court used statutory definitions and rationale; non-statutory instruction was unnecessary and would impermissibly comment on evidence
6. Admission of Seals’s written statements and reenactment video (Miranda, Crawford, hearsay)	Statements were voluntary, Seals was Mirandized and not in custody for reenactment; the statements are party admissions (non-hearsay) or statements against interest	Statements were testimonial/hearsay and violated Fifth Amendment and Confrontation Clause; reenactment lacked on-video Miranda	Admitted – trial court reasonably found voluntary waiver and non-custodial reenactment; Crawford not implicated because declarant (Seals) testified; statements admissible as party admissions or under hearsay exceptions; preservation issues noted for some objections
7. Sufficiency of proof for prior conviction used in enhancement	Certified judgment, other documents, and fingerprint comparison linked Seals to 1994 conviction	Exhibit lacked identifying info linking Seals to judgment	Upheld – totality of evidence (certified documents, fingerprint match, Seals’s admission) proved prior conviction beyond reasonable doubt

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (standard for ineffective assistance of counsel)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial statements and confrontation clause)
De La Paz v. State, 279 S.W.3d 336 (Tex. Crim. App. 2009) (abuse-of-discretion review for evidentiary rulings)
Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1991) (standards for reviewing relevancy and extraneous-offense evidence)
Powell v. State, 63 S.W.3d 435 (Tex. Crim. App. 2001) (State may introduce extraneous offenses to rebut self-defense)
Owens v. State, 827 S.W.2d 911 (Tex. Crim. App. 1992) (limiting instruction must identify the defensive theory tied to extraneous evidence)
Wood v. State, 486 S.W.3d 583 (Tex. Crim. App. 2016) (proof required to link defendant to prior conviction for enhancement)
Flowers v. State, 220 S.W.3d 919 (Tex. Crim. App. 2007) (totality of evidence approach to prove prior convictions)