Jaquel O'Neal v. State, 07-15-00275-CR

Appellant Jacquel O'Neal was tried for multiple counts of injury to a child arising from acts against an infant (pseudonym "Gladus"); appeals in three causes (07-15-00274, -00275, -00276) stem from the same trial as Cause No. 07-15-00273-CR.
The State alleged injuries including cigarette burns, broken ribs, and broken legs, and charged offenses ranging from criminal-negligence bodily injury to serious bodily injury.
Jury instructions included both the charged serious-bodily-injury offenses and lesser-included offenses for bodily injury caused by criminal negligence; verdicts convicted O'Neal of the lesser included offense(s).
Appellant argued the prosecution was void because local prosecutors were disqualified (an issue resolved against him in the companion opinion in Cause No. 07-15-00273-CR).
On sufficiency grounds, O'Neal contested the evidence supporting serious bodily injury (broken ribs/legs, cigarette burn); he did not meaningfully contest that some acts produced at least bodily injury by criminal negligence.
The trial court sentenced O'Neal to two years' state-jail time on each count (suspended) and imposed fines; sentences were suspended in favor of two years' probation.

Issue	Plaintiff's Argument (O'Neal)	Defendant's Argument (State)	Held
Whether prosecution was void because Coryell County DA was disqualified	Prosecutors were disqualified, so trial was void	Prior opinion rejected disqualification; prosecution valid	Overruled — issue decided against O'Neal in companion cause; not sustained
Sufficiency of evidence for conviction in FISC-13-21464 (criminal-negligence bodily injury by cigarette/hand)	Evidence insufficient to prove he caused bodily injury (brief focused elsewhere)	Evidence (including appellant's admission he may have dropped ash on the infant) permits inference of criminal negligence and pain from a cigarette burn	Affirmed — evidence sufficient for criminal-negligence bodily injury
Sufficiency of evidence for convictions in FAM-13-21693 & FAM-13-21694 (serious bodily injury or bodily injury)	Evidence did not establish serious bodily injury (challenged broken ribs/legs and burn)	Jury could convict on either serious bodily injury or lesser bodily injury by criminal negligence based on pushing, striking (red mark), and cigarette burn; bodily injury requires only minor pain	Affirmed — appellant failed to challenge sufficiency for mere bodily injury; evidence supports criminal-negligence bodily injury

Ramsey v. State, 473 S.W.3d 805 (Tex. Crim. App. 2015) (sets current legal-sufficiency standard for reviewing criminal convictions)
Garcia v. State, 367 S.W.3d 683 (Tex. Crim. App. 2012) (any physical pain, however minor, suffices for bodily injury and factfinder may infer pain using common intelligence)