Juan Medina v. State
13-14-00709-CR
| Tex. App. | Apr 14, 2015Background
- Appellant Juan Medina waived jury trial and was tried by the judge on July 1, 2014.
- Medina pled NOT guilty to one count of Aggravated Assault on a Public Servant and NOT guilty to two counts of Assault on a Public Servant.
- Evidence at trial included CCPD officers Soliz, Casas, and Alvarez, plus a civilian witness Robert Medina, describing a confrontation at Medina’s father’s home after Medina had just been released from psychiatric triage.
- Officers testified to a struggle during which Soliz injured his shoulder; Casas was allegedly kicked, and a TASER deployment failed; a pistol observation was later disputed.
- Detective Torres testified he did not include a pistol observation from a civilian witness because the witness was deemed not credible; this allegedly created a purported discrepancy in the report.
- The court convicted Medina on all counts and sentenced him to 15 years for aggravated assault and 3 years on each assault count, all to run concurrently; a motion for new trial/arrest of judgment was filed, and an appeal ensued.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Insufficiency of evidence for counts 1-3 | Medina | State | Evidence insufficient to prove guilt beyond a reasonable doubt |
| Sua sponte consideration of lesser included offenses | Medina | State | Court should have considered lesser included offenses if warranted by evidence |
Key Cases Cited
- Hightower v. State, 389 S.W.2d 674 (Tex.Crim.App.1965) (state bears burden to prove elements beyond reasonable doubt)
- Crocker v. State, 573 S.W.2d 190 (Tex.Crim.App.1978) (indictment allegations proven beyond reasonable doubt)
- Moore v. State, 531 S.W.2d 140 (Tex.Crim.App.1978) (sufficiency test for evidence in criminal cases)
- Houston v. State, 663 S.W.2d 455 (Tex Crim.App.1984) (Jackson v. Virginia standard for sufficiency review)
- Jackson v. Virginia, 443 U.S. 307 (1989) (standard for proving guilt beyond a reasonable doubt)
- Girard v. State, 631 S.W.2d 162 (Tex.Crim.App.[Panel Op]1982) (sufficiency analysis framework in Texas)
- Wilson v. State, 654 S.W.2d 465 (Tex.Crim.App.1985) (applying sufficiency standards to evidence)
- Hall v. State, 158 S.W.3d 470 (Tex.Crim.App.2005) (sua sponte lesser-included offense instruction)