Franjessica Williams v. State
06-14-00224-CR
| Tex. Crim. App. | May 8, 2015Background
- Appellant Franjessica Williams was indicted for injury to a child resulting in serious bodily injury (death of her 2‑year‑old son, J.L.); a jury convicted and sentenced her to 50 years' imprisonment.
- Medical testimony established J.L. died of dehydration and hyperthermia; autopsy showed prominent ribs, flaky lips, extensive fresh bruising, and ligature marks. The medical examiner testified J.L. would have lived with adequate hydration.
- Witnesses and officers testified Appellant admitted spanking and tying up J.L., initially told investigators she found him "tangled in a ribbon," and acknowledged she fed herself but did not feed the child the prior night. Appellant’s apartment was extremely hot.
- Investigators found no ribbons at the scene; the manner Appellant brought J.L. to the hospital and her inconsistent statements were presented as evidence of concealment and culpability.
- Appellant raised three appellate issues: sufficiency of the evidence as to mental state, error in jury instruction regarding good-conduct time, and lack of trial-court jurisdiction.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Sufficiency of evidence to prove intentional/knowing causation of death by failing to provide hydration | Evidence (autopsy, physical signs, admissions, hot apartment, concealment) permits rational inference Appellant knowingly/ intentionally caused death by withholding hydration | Evidence insufficient to prove requisite culpable mental state for result‑oriented offense | Overruled — evidence sufficient for jury to infer intentional/knowing causation |
| Jury instruction on good‑conduct time | Charge complied with statute and explicitly told jurors not to consider speculative effect of good‑conduct time | Instruction was erroneous because Appellant was ineligible for good‑conduct time and violated due process | Overruled — no reversible (egregious) harm; instruction lawful under precedent |
| Trial court jurisdiction (282nd court) | Indictment filed and case adjudicated in 282nd court; filing determines jurisdiction despite grand jury impaneled by different court | Argued lack of jurisdiction because grand jury was impaneled by another district court | Overruled — 282nd had jurisdiction; indictment filed there and case not transferred elsewhere |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App.) (appellate sufficiency review framing)
- Luquis v. State, 72 S.W.3d 355 (Tex. Crim. App.) (approving statutory good‑conduct time jury instruction practice)
- Atkinson v. State, 107 S.W.3d 856 (Tex. App. – Dallas) (no confusion from similar good‑conduct time charge)
- Bourque v. State, 156 S.W.3d 675 (Tex. App. – Dallas) (discussion of filing/assignment and district court jurisdiction)