James Michael Reser v. State, 03-15-00469-CR

Defendant James Michael Reser and complaining witness Amanda Taylor were in a relationship and lived together with children; Taylor had previously filed a missing-person report after Reser left home.
On April 28, 2012, Reser attacked Taylor: grabbed her from behind, struck her, and injected her multiple times with a syringe; Taylor suffered swelling and eight puncture wounds.
Reser then barricaded himself, Taylor, and their two children in a bedroom; police negotiated for about an hour.
While barricaded, Reser again struck Taylor and repeatedly pulled a large, partly serrated fixed-blade knife in and out of its sheath within Taylor’s view; he told officers he had a gun and warned the situation might get "worse."
Police eventually took Reser into custody; the syringe tested positive for cocaine.
A jury convicted Reser of aggravated assault with a deadly weapon and unlawful restraint with exposure to a substantial risk of serious bodily injury; the court sentenced him to concurrent prison terms and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of deadly-weapon finding	State: knife (and/or syringe) was exhibited and was capable of causing serious injury	Reser: evidence insufficient to show an object was a deadly weapon	Affirmed — jury could find the knife was a deadly weapon based on its characteristics and use
Sufficiency for aggravated assault	State: Reser threatened Taylor with imminent bodily injury and used a deadly weapon	Reser: no proof of threat or deadly-weapon use	Affirmed — evidence of attack, threats, knife display, and injuries supported conviction
Sufficiency for unlawful restraint (recklessly causing substantial risk of serious bodily injury)	State: Reser restrained Taylor and injected her with cocaine and threatened with a knife, creating substantial risk	Reser: evidence insufficient to show reckless exposure to substantial risk	Affirmed — barricading, forcible injection of cocaine, threats, and refusal to allow treatment supported the finding
Exclusion of post‑incident impeachment evidence	Reser: trial court erred in excluding evidence of Taylor’s post-arrest conduct and messages that could impeach credibility	State: evidence was prejudicial and its probative value was outweighed; trial court within discretion	Affirmed — even if exclusion were error, it was harmless given corroborating evidence (mother’s eyewitness account, officers’ statements, weapons, and injuries)

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for legal sufficiency review)
Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (view evidence in light most favorable to verdict)
Robertson v. State, 163 S.W.3d 730 (Tex. Crim. App. 2005) (knife characteristics can establish deadly-weapon status)
Thompson v. State, 408 S.W.3d 614 (Tex. App.—Austin 2013) (knife admitted into evidence supports conclusion it could cause serious harm)
Schmutz v. State, 440 S.W.3d 29 (Tex. Crim. App. 2014) (harmless‑error standard for nonconstitutional errors)
Lucio v. State, 351 S.W.3d 878 (Tex. Crim. App. 2011) (appellate courts do not perform factual‑sufficiency review)
Thomas v. State, 444 S.W.3d 4 (Tex. Crim. App. 2014) (use of a hypothetically correct jury charge when assessing sufficiency)