424 S.W.3d 140
Tex. App.2014Background
- Jackson was convicted of capital murder for killing and sexually assaulting Marchand, a 60-year-old mentally challenged woman, and was sentenced to life without parole.
- The indictment alleged capital murder occurred during burglary and/or aggravated sexual assault.
- Evidence showed Marchand’s apartment had no forced entry; items missing; Marchand’s body found in a closet; medical examiner linked ligature strangulation and sexual assault injuries to the offense.
- Detectives arrested Jackson after fingerprint results; Jackson gave multiple statements (three oral, one written) after arrest; police conducted several interviews and a polygraph-related interview.
- The trial court denied suppression of Jackson’s statements; the Fifth Circuit affirmed the court’s determination that statements were voluntary under Article 38.22 and Miranda rights were properly administered.
- On appeal, Jackson challenged sufficiency of the capital murder evidence, voluntariness of statements, and Rule 403 objections to exhibits; the court affirmed the trial court’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the evidence legally sufficient for capital murder? | Brooks argues no burglary element evidence. | Jackson contends lack of burglary and no intent to murder. | Yes; burglary proven; need only one underlying felony. |
| Were Jackson's oral and written statements voluntary? | Brooks contends coercion and improper waiver. | Jackson argues involuntary confession. | Yes; statements voluntary; trial court’s denial of suppression affirmed. |
| Do Jackson's Rule 403 objections require reversal? | Brooks asserts error in admitting various exhibits. | Jackson argues balancing test not performed. | No reviewable error; issues forfeited or inadequately briefed. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing evidentiary sufficiency)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for sufficiency, juries’ resolution of conflicts)
- Estrada v. State, 313 S.W.3d 274 (Tex. Crim. App. 2010) (holding on voluntariness and Denno analysis)
- Murphy v. State, 112 S.W.3d 592 (Tex. Crim. App. 2003) (Article 38.22 compliance and finding of voluntariness)
- Santellan v. State, 939 S.W.2d 155 (Tex. Crim. App. 1997) (balancing and/testing for Rule 403 applicability)