James Preston Bales v. State, 12-16-00048-CR

On March 6, 2015, James Preston Bales struck Bias Lott with a baseball bat; Lott died the next day.
Bales was arrested and charged with murder.
At trial Bales asserted he acted in self‑defense, claiming Lott had a knife.
The trial court submitted a jury charge including self‑defense and "reasonable belief" instructions derived from the Texas Penal Code.
The jury convicted Bales of murder and imposed a life sentence. Bales appealed, arguing the self‑defense instruction was inaccurate and incomplete.
The Court of Appeals considered whether the charge erred and, if so, whether any error required reversal under Texas standards for jury‑charge review.

Issue	Bales' Argument	State's Argument	Held
Whether the jury charge’s self‑defense instruction was inaccurate/incomplete because it omitted statutory definitions	The charge failed to include the Penal Code definitions of "self‑defense" and "deadly conduct in self‑defense," rendering it incomplete	The charge tracked the Penal Code by instructing that deadly force is justified when a person reasonably believes it is immediately necessary and by defining "reasonable belief"	Court held no error: the instructions tracked the statutory definitions and preserved Bales’ self‑defense rights; conviction affirmed

Abdnor v. State, 871 S.W.2d 726 (Tex. Crim. App. 1994) (two‑step jury‑charge review: error then harm)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1984) (harm standards for charge error and factors for assessing harm)
Walters v. State, 247 S.W.3d 204 (Tex. Crim. App. 2007) (instructions not derived from Penal Code are not applicable law under article 36.14)
Bundy v. State, 280 S.W.3d 425 (Tex. App.—Fort Worth 2009) (self‑defense rights preserved when charge states justification and defines reasonable belief)
Valentine v. State, 587 S.W.2d 399 (Tex. Crim. App. 1979) (principles on self‑defense jury instructions)