Justin Ross Allen v. State, 14-14-00844-CR

Appellant and victim were coworkers and motel roommates; appellant’s father supervised their job. Victim was found dead wrapped in a blanket on the motel room floor with blunt-force head injuries.
Police found the victim’s bedding removed and soaking in the bathtub, blood on the headboard and the sheet covering the body, and a hammer wrapped in two plastic bags in the motel room trash.
Appellant admitted hitting the victim twice in the back of the head with a hammer, then covered the body, soaked bedding, bagged the hammer, and fled the scene; he was later located and bitten by a police dog and treated for the bite.
Appellant testified he acted in self-defense, alleging the victim had attempted a sexual assault (he described being grabbed and feeling semen) and that the victim had been on top of him when he struck with the hammer.
The jury convicted appellant of murder; on appeal he challenged sufficiency of the evidence as to (1) intent to kill and (2) the State’s proof rebutting self-defense. The Fourteenth Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Allen)	Held
Sufficiency to prove intent to kill	Evidence of buying/retrieving hammer, admitted blows to head, attempts to conceal weapon and bedding, and flight support inference of intent	Appellant argued testimony was self-defense and lack of evidence he intended to kill	Affirmed — jury could infer intent from weapon acquisition, concealment, and flight
Sufficiency to disprove self-defense beyond reasonable doubt	Once Allen raised self-defense, State had burden to persuade jury; physical evidence (blows to back of head, blood pattern, removed bedding) undermined his account	Allen argued physical evidence and lack of motive made self-defense reasonable and should not have been rejected	Affirmed — evidence, viewed in prosecution’s favor, permits jury to reject self-defense

Alonzo v. State, 353 S.W.3d 778 (Tex. Crim. App. 2011) (self-defense need not require intent to kill)
Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (concealment, inconsistent statements, and implausible explanations are probative of guilt)
Zuliani v. State, 97 S.W.3d 589 (Tex. Crim. App. 2003) (defendant must produce some evidence of self-defense; State must then persuade jury beyond reasonable doubt)
Saxton v. State, 804 S.W.2d 910 (Tex. Crim. App. 1991) (credibility determinations for defensive evidence are for the jury)
Brown v. State, 122 S.W.3d 794 (Tex. Crim. App. 2003) (intent is a question of fact for the jury)