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Francis, Jeremy M.
PD-0860-15
| Tex. App. | Oct 16, 2015
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Background

  • Jeremy M. Francis was convicted of capital murder for the September 16, 2011 stabbing death of Martin Coronado and sentenced to life without parole; the Fifth Court of Appeals affirmed (modified judgment language to indicate life without parole).
  • Investigation initially produced only a trail of bloody footprints at the scene and no eyewitnesses or surveillance video.
  • Five days later (Sept. 21, 2011) covert officers observed Francis and William Langrum commit an aggravated robbery; a vehicle/foot chase led to their arrest and recovery of a knife and clothing.
  • Forensic testing linked Coronado to a stain on Francis’s right shoe (DNA match probability cited by the lab) and linked Langrum to other clothing/knife samples; cell‑tower records placed calls from Francis’s phone near the crime area around the time of the murder.
  • The State introduced testimony about the Sept. 21 aggravated robbery and evading/flight to explain how police located the suspects and recovered the knife and clothing; Francis objected under Rules 401, 402, 403, and 404(b).
  • The trial court admitted the extraneous‑offense evidence; on appeal Francis argued the admission violated Rules 404(b) and 403 by prejudicing the jury and suggesting propensity.

Issues

Issue Francis's Argument State's Argument Held
Admissibility of Sept. 21 extraneous offenses under Tex. R. Evid. 404(b) and 403 Admission improperly allowed propensity inference; prejudicial and outweighed probative value Evidence was same‑transaction/contextual and necessary to explain how police recovered the knife and clothing; minimal prejudice Court affirmed: evidence admissible as same‑transaction contextual evidence and not excluded under Rule 403

Key Cases Cited

  • Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1990) (Rule 403 balancing presumption favoring admissibility)
  • Martinez v. State, 327 S.W.3d 727 (Tex. Crim. App. 2010) (abuse‑of‑discretion standard for evidentiary rulings)
  • De La Paz v. State, 279 S.W.3d 336 (Tex. Crim. App. 2009) (proponent must explain non‑propensity rationale for extraneous‑acts evidence)
  • Rogers v. State, 853 S.W.2d 29 (Tex. Crim. App. 1993) (contextual/same‑transaction evidence doctrine)
  • Devoe v. State, 354 S.W.3d 457 (Tex. Crim. App. 2011) (same‑transaction contextual evidence admissible when offenses are interwoven)
  • Moreno v. State, 721 S.W.2d 295 (Tex. Crim. App. 1986) (jury entitled to surrounding facts; offense not tried in a vacuum)
  • Gigliobianco v. State, 210 S.W.3d 637 (Tex. Crim. App. 2006) (refined six‑factor Rule 403 analysis)
  • Mozon v. State, 991 S.W.2d 841 (Tex. Crim. App. 1999) (Rule 403 exclusion grounds)
  • Williams v. State, 958 S.W.2d 186 (Tex. Crim. App. 1997) (presumption that trial judge performed Rule 403 balancing)
  • Santellan v. State, 939 S.W.2d 155 (Tex. Crim. App. 1997) (same presumption regarding Rule 403 balancing)
Read the full case

Case Details

Case Name: Francis, Jeremy M.
Court Name: Court of Appeals of Texas
Date Published: Oct 16, 2015
Docket Number: PD-0860-15
Court Abbreviation: Tex. App.