John Joe Camacho v. the State of Texas, 01-20-00282-CR

Camacho and Debbie were parents of two children and had a long-term volatile relationship marked by repeated physical abuse spanning years (including incidents while Debbie was pregnant, a 2015 choking incident, and a 2017 tussle). Photos and police testimony documented injuries from prior incidents.
On November 17, 2018, Debbie testified Camacho strangled her, held her in a headlock, and later swiped a knife that grazed her leg; Camacho testified he disarmed Debbie and restrained her to deescalate.
A two-count indictment charged family-violence assault by impeding breathing and aggravated assault with a deadly weapon (knife); the jury acquitted on the choking count and convicted on aggravated assault with a deadly weapon.
The trial court admitted testimony and photographic evidence of multiple prior incidents of domestic violence against Debbie under Tex. Code Crim. Proc. art. 38.371, plus expert testimony on the cycle of domestic abuse; the court repeatedly gave a limiting instruction that extraneous-offense evidence could be considered only to show the nature of the relationship.
Camacho was sentenced to 20 years; he appealed, arguing the trial court abused its discretion by admitting extraneous-act evidence in violation of Tex. R. Evid. 404(b) and 403.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by admitting evidence of Camacho's extraneous acts of domestic violence during guilt-innocence	Evidence of prior abuse is admissible under art. 38.371 to explain the nature of the relationship and why the victim recanted or was reluctant to cooperate; expert testimony would contextualize victim behavior	Prior-act evidence was improper 404(b) character-conformity evidence and, even if relevant, should have been excluded under Rule 403 as unfairly prejudicial and cumulative	Affirmed: trial court acted within its discretion—extraneous acts were admissible under art. 38.371 for non-character purposes (contextualizing relationship and explaining recantation/hesitancy); Rule 403 balancing did not require exclusion given probative value and limiting instructions

Martinez v. State, 327 S.W.3d 727 (Tex. Crim. App. 2010) (standard of review for admissibility: abuse of discretion)
De La Paz v. State, 279 S.W.3d 336 (Tex. Crim. App. 2009) (review of extraneous-offense admissibility and 404(b) principles)
Dabney v. State, 492 S.W.3d 309 (Tex. Crim. App. 2016) (trial-court ruling review: zone of reasonable disagreement)
Devoe v. State, 354 S.W.3d 457 (Tex. Crim. App. 2011) (Rule 404(b) permits extraneous-offense evidence when relevant for non-character purposes)
Fernandez v. State, 597 S.W.3d 546 (Tex. App.—El Paso 2020) (article 38.371 authorizes extraneous-offense evidence to explain victim recantation and relationship context)
Gigliobianco v. State, 210 S.W.3d 637 (Tex. Crim. App. 2006) (Rule 403 balancing framework)
Shuffield v. State, 189 S.W.3d 782 (Tex. Crim. App. 2006) (presumption favoring admission of relevant evidence)
Hammer v. State, 296 S.W.3d 555 (Tex. Crim. App. 2009) (Rule 403 exclusion requires clear disparity between prejudice and probative value)
Lane v. State, 933 S.W.2d 504 (Tex. Crim. App. 1996) (limiting instructions can reduce risk of impermissible character-conformity inferences)
Kiser v. State, 893 S.W.2d 277 (Tex. App.—Houston [1st Dist.] 1995) (factors for probative value of prior misconduct: temporal proximity, similarity, need)