James Wilbur Higgins v. State, 13-17-00456-CR

In December 2015, James Wilbur Higgins’s SUV and Julius Hjulian’s tricycle interacted on the road after a history of ongoing animosity; Hjulian ended up on the ground and later sought medical treatment.
Witnesses described mutual gestures, a loud "thump" against the SUV, visible blue paint on the tricycle, and a fresh gouge on Higgins’s vehicle; testimony conflicted about whether a collision occurred or Hjulian kicked the vehicle.
Higgins fled the scene without exchanging information; he later went to the sheriff’s office and spoke with Officer Chapa.
Higgins had an existing civil suit against Hjulian and argued the suit and long-term hostility showed Hjulian’s bias and that he left the scene out of fear of imminent harm.
Trial court sustained State objections limiting inquiry into the details of the civil suit; the court also refused Higgins’s requested jury instruction on the defense of necessity.
The jury convicted Higgins of failure to stop and render aid (Tex. Transp. Code § 550.021); punishment was suspended and community supervision imposed. Appeal followed.

Issue	Higgins' Argument	State's Argument	Held
Exclusion of evidence about Higgins’s civil suit against Hjulian	Trial court wrongly prevented admission of civil-suit details to show Hjulian’s bias	Evidence of hostility and the existence of the suit were already before jury; detailed civil-suit probing would be cumulative and confusing	No abuse of discretion in limiting detailed inquiry; issue overruled
Denial of necessity instruction	Higgins argued necessity applied because he reasonably believed Hjulian was drawing a weapon, so leaving was immediately necessary	Necessity requires admission of the charged conduct (confession-and-avoidance); Higgins did not admit the offense or the required culpable mental state	Necessity instruction not warranted because Higgins did not admit to the offense; issue overruled
Denial of directed verdict	Higgins asserted trial court erred in denying his motion for directed verdict	State relied on sufficiency of evidence submitted to jury	Issue inadequately briefed on appeal; court declined to address it

Johnson v. State, 490 S.W.3d 895 (Tex. Crim. App. 2016) (abuse of discretion standard for evidentiary rulings)
Hammer v. State, 296 S.W.3d 555 (Tex. Crim. App. 2009) (limits on cross-examination for bias and rule 403 analysis)
Billodeau v. State, 277 S.W.3d 34 (Tex. Crim. App. 2009) (witness animus is relevant and defendant may show bias subject to reasonable restrictions)
Juarez v. State, 308 S.W.3d 398 (Tex. Crim. App. 2010) (confession-and-avoidance doctrine for necessity defense)
United States v. Coleman, 997 F.2d 1101 (5th Cir. 1993) (evidence of longstanding mutual antagonism can inform witness bias)
Brown v. United States, 217 F.3d 247 (5th Cir. 2000) (trial court may limit cross-examination into civil suits when jury already apprised of antagonism)