James R. Thompson v. State
425 S.W.3d 480
| Tex. App. | 2012Background
- Thompson was convicted of murder of Giselle Teapo and sentenced to life; an enhancement for a prior federal cocaine conviction and a deadly-weapon finding were part of the judgment.
- Thompson and Teapo lived together; Teapo planned to report Thompson’s harassing phone calls to his parole officer.
- Witnesses described a violent incident where Thompson choked Teapo; Teapo sustained injuries and subsequently moved out with her children.
- A neighbor identified Thompson near the crime scene in a blue Dodge Intrepid an hour before Teapo’s murder; Thompson had recently bought a blue Dodge Intrepid.
- Evidence included Thompson’s mobile phone records showing activity near the murder scene and then the route toward his home, suggesting proximity to the crime.
- During punishment, the State introduced extraneous-arson evidence; investigators testified the fire was intentional and Thompson claimed to have changed the locks.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the murder evidence | Evidence was wholly circumstantial and stacked inferences. | Jackson standard allows circumstantial evidence; total evidence supports guilt. | Evidence legally sufficient; verdict affirmed. |
| Admissibility of mobile-phone-record expert testimony | Testimony unhelpful and the witness lacked qualifications. | Gatekeeping under Rule 702; witness qualified and testimony helpful. | Admissible; no abuse of discretion. |
| Admissibility of arson evidence during punishment | Arson evidence not proven beyond a reasonable doubt; improper for punishment phase. | Extraneous-offense evidence relevant to sentencing under Article 37.07; sufficientcircumstantial proof. | Admissible; evidence supports sentencing considerations. |
| Sufficiency of arson evidence for punishment | Do not review sufficiency of extraneous-offense evidence for punishment; issue foreclosed. | Evidence admissible if defendant involved; need not prove a crime beyond reasonable doubt for punishment. | Do not reverse on sufficiency; admissibility upheld. |
Key Cases Cited
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (inference stacking not a separate standard; use Jackson review)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (traditional sufficiency standard for criminal statutes)
- Coble v. State, 330 S.W.3d 253 (Tex. Crim. App. 2010) (Daubert-style gatekeeping for expert testimony)
- Kelly v. State, 824 S.W.2d 568 (Tex. Crim. App. 1992) (gatekeeping and Rule 702 framework for expert evidence)
- Emerson v. State, 880 S.W.2d 759 (Tex. Crim. App. 1994) (helpfulness and Rule 702 balancing test)
- Joiner v. State, 825 S.W.2d 701 (Tex. Crim. App. 1992) (classification of expert testimony admissibility under 702)
- Davis v. State, 329 S.W.3d 798 (Tex. Crim. App. 2010) (two-step qualification of expert under Rule 702)
- Rodgers v. State, 205 S.W.3d 525 (Tex. Crim. App. 2006) (complexity-based qualification standard for experts)
- Smith v. State, 227 S.W.3d 753 (Tex. Crim. App. 2007) (context for extraneous-offense evidence during punishment)