in Re Commitment of Rudy Perez, 09-15-00126-CV

The State petitioned to commit Perez as a sexually violent predator under Tex. Health & Safety Code §§ 841.001-.151; the trial court granted a final judgment and order of civil commitment after a jury verdict.
Perez admitted to prior indecency with a child (F.A., 1993) and to related offenses under admissions requests; he testified to prior convictions and alcohol-related factors.
Arambula, a forensic psychiatrist, testified Perez has a behavioral abnormality and multiple risk factors for sexual reoffending, with diagnoses including paraphilia and alcohol dependence.
Perez testified about his offenses, alcohol use, and his claims of responsibility and plans to refrain from reoffending if released.
The trial court granted the State’s motion for a directed verdict on repeat SV offender; the jury found Perez is a sexually violent predator, supporting commitment.
Perez appeals two issues: improper jury argument and error in jury instruction about unanimity of a ‘no’ finding

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State’s closing argument was improper	Perez argues the State’s argument exceeded the scope of defense closing	State contends arguments were a proper summary/response to evidence	No reversible error; argument was proper or harmless
Whether the jury charge required unanimity for a ‘no’ finding	Perez claims no unanimous verdict needed for a ‘no’ finding per § 841.062(b) and Rule 292	State argues statute only requires unanimous verdict for a finding of SVP; error, if any, harmless	No reversible error; instruction error, if any, was not shown to be harming the judgment

In re Commitment of Eeds, 254 S.W.3d 555 (Tex. App.—Beaumont 2008) (standard for reviewing jury argument error frameworks)
In re Commitment of Dodson, 434 S.W.3d 742 (Tex. App.—Beaumont 2014) (proper scope of closing arguments; review of preservation and harmlessness)
Transcon. Ins. Co. v. Crump, 330 S.W.3d 211 (Tex. 2010) (review of whether an error probably caused an improper judgment)
Quantum Chem. Corp. v. Toennies, 47 S.W.3d 473 (Tex. 2001) (consideration of evidence sufficiency and harmlessness for error)
In re Commitment of Almaguer, 117 S.W.3d 500 (Tex. App.—Beaumont 2003) (harmless-error standard under Rule 44.1)