in the Matter of M.W., a Juvenile, 12-15-00096-CV

Juvenile M.W. was charged by the State under Tex. Penal Code § 36.06 after a school fight in which she struck two teachers who intervened to separate her from another student, J.G.
At trial M.W. pleaded not true; a jury found she committed the offense of retaliation (harming public servants) and the court placed her on ten months’ community supervision.
Teachers Tena Hill and Rhonda Johnson testified M.W. hit Johnson in the face (breaking her glasses), rolled on the floor with her, and later struck Hill in the head/neck and upper body while J.G. was subdued.
M.W. testified she is legally blind without glasses, that J.G. had bullied her and started the fight, that she did not remember hitting teachers, and claimed she believed a student was grabbing her.
The court reviewed sufficiency of the evidence under the criminal (Jackson) standard because the appeal challenges adjudication of delinquency, not disposition.
The court affirmed, holding evidence was legally sufficient to show M.W. intentionally or knowingly harmed the teachers because they were discharging their duties as public schoolteachers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for retaliation (Tex. Penal Code §36.06)	State: evidence shows M.W. intentionally/knowingly struck teachers because they were performing their duties	M.W.: legally blind without glasses; didn’t identify teachers; thought another student was attacking her — no proof she hit teachers "on account of" their public-serving status	Court: Affirmed — a rational jury could infer she hit teachers because they were attempting to discharge their duties; "on account of" means "because of"
Self‑defense as to lesser included offense (assault)	N/A (State prevailed on retaliation)	M.W.: if retaliation fails, self-defense should acquit as to assault	Court: Did not reach merits because retaliation adjudication was upheld; issue overruled as moot

Jackson v. Virginia, 443 U.S. 307 (legal sufficiency standard for criminal convictions)
Brooks v. State, 323 S.W.3d 893 (deference to jury credibility in sufficiency review)
Malik v. State, 953 S.W.2d 234 (use of hypothetically correct jury charge in sufficiency analysis)
McCoy v. State, 932 S.W.2d 720 (interpreting "on account of" public‑servant element without requiring retributory purpose)
In re M.M.R., 932 S.W.2d 112 (contrasting line holding retributory purpose required)
Nandin v. State, 402 S.W.3d 404 (rejecting requirement of retributory purpose for §36.06)