Jackson, Willie Frank, PD-0699-15

On May 21, 2013, Willie Frank Jackson shot Steven Ray Cook in the leg during an encounter at an apartment complex, pointed a gun at Cook, demanded the location of Cook’s wallet, and was seen rifling through Cook’s truck console. The wallet was later found along Jackson’s route of departure missing $40; a small .22 handgun that had been in the truck console was also missing.
Jackson was tried by jury, convicted of aggravated robbery, and, after habitual-offender enhancement, sentenced to 90 years’ imprisonment.
On appeal, Jackson challenged (1) the legal sufficiency of the evidence to prove the theft element of aggravated robbery and (2) trial-court conduct in allowing him to remove his shirt while wearing a visible electronic shock belt during the punishment phase (claiming lack of on-the-record findings justifying the restraint).
The court reviewed legal-sufficiency under the Jackson/Brooks standard (all evidence viewed in the light most favorable to the verdict) and the hypothetically correct jury charge framework (Malik).
The court affirmed: it found the evidence sufficient for a rational juror to infer Jackson committed the theft during the robbery, and it held Jackson failed to preserve the electronic-restraint complaint because defense counsel did not make a timely, specific objection or obtain a ruling.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jackson)	Held
Sufficiency of evidence to prove theft element of aggravated robbery	Evidence (victim saw Jackson rifling through truck, wallet later found on Jackson’s path missing $40, gun missing) supports jury inference of theft	Victim’s vision impaired by blood; friend had access to truck and truck could have been left unlocked; no direct proof Jackson took money or gun	Affirmed — viewing evidence in favor of verdict, rational juror could find theft beyond reasonable doubt
Visible electronic restraint during punishment phase	No objection was made at trial; record lacks on-the-record justification for restraint, so issue not preserved	Jackson argued restraint was visible to jury and trial court failed to make specific findings justifying its use, requiring a new punishment trial	Issue not preserved — defense counsel did not make a specific objection or obtain a ruling; claim overruled

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for reviewing legal sufficiency of the evidence)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (due-process standard for sufficiency: whether any rational trier of fact could find guilt beyond a reasonable doubt)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (jury’s role in weighing evidence and drawing inferences)
Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (hypothetically correct jury charge governs sufficiency review)
Deck v. Missouri, 544 U.S. 622 (U.S. 2005) (constitutional limits on visible restraints; restraints visible to the jury require courtroom judicial justification)