Jonathan Baker v. State, 12-14-00185-CR

Joniah Baker, born 12/29/2010, was in appellant’s sole care on December 7, 2011, when he was brought to the hospital after sustaining extensive injuries.
Joniah exhibited multiple injuries including 26 burns and serious head injuries; a medical team concluded the injuries were consistent with abuse and a severe trauma event.
Appellant provided inconsistent, shifting explanations for Joniah’s injuries to detectives; his accounts failed to account for the extent and pattern of injuries observed by medical staff.
An autopsy determined the cause of death as a homicide due to a fatal head injury, with extensive burns contributing to the condition.
The State relied on forensic evidence to argue that appellant acted intentionally or knowingly to cause Joniah’s death, with DNA evidence linking under fingernails to the scene.
Appellant was convicted of capital murder of a child under ten and sentenced to life imprisonment without the possibility of parole; no death penalty was sought.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence legally sufficient to prove death caused intentionally or knowingly?	Baker contends insufficiency to prove death and mental state.	Baker argues death could have resulted from prior injuries or non-intentional acts.	Yes; evidence supports intentional/knowingly causing death.
Did the trial court err by admitting an undisclosed witness (Dr. Nesiama) without proper notice?	Baker preserved error and discovery violation; admission prejudicial.	State complied with discovery or Baker forfeited by failure to request continuance.	Procedural fault was forfeited; even if preserved, court did not err in admitting testimony.
If preserved, did the admission of the undisclosed witness violate constitutional rights?	Baker asserts confrontation/neutral-judge rights were violated.	No constitutional violation given disclosure context and trial court remedies.	No reversible error; rights not violated under the record.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for legal-sufficiency review)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (restricts appellate reweighing of evidence; trusts jury verdict)
Isassi v. State, 330 S.W.3d 633 (Tex. Crim. App. 2010) (standard for evaluating sufficiency in light of the record)
Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (deference to jury’s inferences; circumstantial evidence)
Geesa v. State, 820 S.W.3d 154 (Tex. Crim. App. 1991) (abandoned reasonable-hypothesis analysis for circumstantial cases)
Louis v. State, 393 S.W.3d 246 (Tex. Crim. App. 2012) (limits on inferring intent when multiple actors contribute)
Merritt v. State, 368 S.W.3d 516 (Tex. Crim. App. 2012) (evaluates sufficiency and credibility when multiple theories exist)
Cuadros–Fernandez v. State, 316 S.W.3d 645 (Tex. App.—Dallas 2009) (left-alone-child injury sufficiency in capital murder context)
Patrick v. State, 906 S.W.2d 481 (Tex. Crim. App. 1995) (mental-state inferences from circumstances)