Franjessica Williams v. State
06-14-00224-CR
| Tex. Crim. App. | Apr 1, 2015Background
- Appellant Franjessica Williams was charged with injury to a child by omission, alleging dehydration and failure to seek medical care caused death.
- The indictment alleges Williams, as mother, had a statutory duty to act for J.L., a child 14 or younger.
- Trial jury found Williams guilty of the indicted offense and set punishment at 50 years in prison.
- Williams challenged the sufficiency of the evidence for the culpable mental state, the good conduct time instruction, and the trial court's jurisdiction.
- Extensive trial testimony and expert impeachment focused on Williams's intellectual functioning and disciplinary practices.
- Evidence showed J.L. died of dehydration and hyperthermia with extensive injuries; defense argued lack of knowing intent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Culpable mental state sufficiency | Williams | State | Insufficient mental-state proof for knowing conduct |
| Good conduct time instruction | Williams | State | Instruction erroneous; inapplicable credit mattered; reversible error |
| Judicial jurisdiction transfer | Williams | State | Lack of docket transfer voids judgment; jurisdiction improper |
Key Cases Cited
- Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (two standards of harm for charge errors)
- Becthard v. State, 767 S.W.2d 423 (Tex. Crim. App. 1989) (harm standard for article 36.19 review)
- Ex parte Seidel, 39 S.W.3d 221 (Tex. Crim. App. 2001) (jurisdictional and procedural error can be raised on appeal)
- Jimenez v. State, 992 S.W.2d 633 (Tex. App.—Houston [1st Dist.] 2000) (parole instruction error; harmless error standard for non-objected errors)
- Jackson v. Virginia, 443 U.S. 307 (1979) (due process standard for sufficiency; rationality of verdict)
- Marin v. State, 851 S.W.2d 275 (Tex. Crim. App. 1993) (jurisdictional and presentment considerations)
- Ovalle v. State, 13 S.W.3d 774 (Tex. Crim. App. 2000) (harm analysis for charge errors; non-structural)
- Jimenez v. State, 32 S.W.3d 233 (Tex. Crim. App. 2000) (standard for harm in error to parole instruction)
- Sparks v. State, WL 42285 (Tex. App.—Dallas 2001) (analysis of missing harm requirement)
- Warner v. State, Nos. P.D.-1680-05, P.D.-16801-05 (Tex. Crim. App. 2008) (general harm assessment for trial errors)