Jeffery Noblett v. State
07-14-00412-CR
| Tex. App. | Sep 30, 2015Background
- Appellant Noblett was convicted of aggravated kidnapping with a 50-year sentence and $10,000 fine.
- Evidence shows Hooser, involved with a meth ring, was beaten, bound, and transported after a dispute over a drug deal.
- Noblett assisted by acting as lookout, retrieving binding wire, and helping load Hooser; he later agreed to pursue further retaliation.
- Hooser was ultimately killed; state evidence suggests Burns shot Hooser and Melton participated in the assault.
- The state sought to prove aggravated kidnapping under Section 20.04(a)(5) and party liability under Texas law.
- The trial court admitted evidence and charged the jury on law of parties; Noblett appeals on evidentiary, sufficiency, and charge issues; the court affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for aggravated kidnapping | Noblett contends evidence insufficient | State contends evidence supports all elements | Sufficient evidence; conviction affirmed |
| Law of parties jury charge adequacy | Charge misapplied party liability rules | Charge correctly authorized party liability | Charge proper; no reversible error |
| Admission of murder evidence and photographs | Evidence inadmissible/prejudicial | Evidence admissible under same-transaction context | Admission not abuse of discretion; evidence proper |
| Motion in limine regarding murder evidence | Motion in limine improperly denied | Motion preserved via trial objections | Issue unreviewable on appeal; other points resolve the matter |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for appellate review of sufficiency of evidence)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) ( Jackson standard applied to defer to jury credibility)
- Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (Presents Almanza standard for juror-charge error)
- Ngo v. State, 175 S.W.3d 738 (Tex. Crim. App. 2005) (reversal when egregious harm from improper charge)
- Hinojosa v. State, 433 S.W.3d 742 (Tex. App.—San Antonio 2014) (defines party liability under Tex. Penal Code §7.01–7.02)
- Ransom v. State, 920 S.W.2d 288 (Tex. Crim. App. 1996) (evidence may support both primary and party theories)
- Camacho v. State, 864 S.W.2d 524 (Tex. Crim. App. 1993) (same-transaction contextual evidence admissible to illuminate crime)
- Rogers v. State, 853 S.W.2d 29 (Tex. Crim. App. 1993) (intrinsic evidence and contextual integration of offenses)
- Gigliobianco v. State, 210 S.W.3d 637 (Tex. Crim. App. 2006) (Rule 403 balancing for photographic evidence)
- Sonnier v. State, 913 S.W.2d 511 (Tex. Crim. App. 1995) (photographic evidence not automatically prejudicial)
- Beier v. State, 687 S.W.2d 2 (Tex. Crim. App. 1985) (presence alone insufficient for party liability)