Background

• Josue Morales was charged and convicted of continuous violence against the family, specifically for assaults on Eva Casarez (with whom he had a dating relationship and shared a child) during two incidents within a twelve-month period.
• The October 2021 incident involved Morales allegedly backhanding Casarez multiple times in the face, causing visible injuries, and pushing her head into a dashboard.
• The February 2022 incident involved Morales allegedly physically restraining Casarez, squeezing her for an extended time, and backhanding her in the face, resulting in further visible injuries.
• Casarez’s account was supported by photographic evidence and corroborating testimony from law enforcement and Morales's brother.
• Morales appealed, arguing the evidence was insufficient to prove he intentionally, knowingly, or recklessly caused bodily injury.
• The trial court’s judgment was affirmed by the Eleventh Court of Appeals, which reviewed the sufficiency of the evidence in the light most favorable to the verdict.

Issues

Key Cases Cited

• Jackson v. Virginia, 443 U.S. 307 (1979) (establishes the standard for legal sufficiency of evidence in criminal cases)
• Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (clarifies legal sufficiency standard under Jackson for Texas criminal cases)
• Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (bodily injury can include even minor pain; factfinder infers pain from evidence)
• Bolton v. State, 619 S.W.2d 166 (Tex. Crim. App. 1981) (testimony on victim’s injuries sufficient to prove bodily injury)
• Dewberry v. State, 4 S.W.3d 735 (Tex. Crim. App. 1999) (deference to jury’s credibility determinations in sufficiency review)