Karra Trichele Allen v. State, 03-15-00420-CR

Appellant Karra Trichele Allen was convicted by a jury of murder for fatally shooting her husband and sentenced to life imprisonment.
At trial, the court submitted self-defense instructions to the jury; Allen did not object to the charge at the charge conference.
On appeal Allen argued the jury charge omitted statutory self-defense language (including the presumption of reasonableness), contained extra-statutory language about provocation, and that cumulative errors violated due process.
The Court of Appeals reviews unpreserved charge error for egregious harm and requires specific requests/objections to preserve defensive instructions.
The appellate court found no record that Allen requested the omitted self-defense variants and held the provocation instruction substantially tracked the statute.

Issue	Allen's Argument	State's Argument	Held
1. Omission of statutory self-defense language (e.g., presumption of reasonableness)	The charge omitted large portions of Penal Code §9.32, including the presumption that deadly force was reasonable under certain circumstances	Allen failed to specifically request those statutory formulations at trial; no preservation	Forfeited; no error shown because Allen did not request the omitted instructions
2. Omission of other self-defense provisions	The jury was not asked to decide entitlement to statutory presumptions/alternate justifications	Same—defensive instructions must be requested and specific enough to put court on notice	Forfeited for same reasons as Issue 1
3. Extra‑statutory language re: verbal provocation	The court’s wording was a prohibited comment on the weight of the evidence and caused egregious harm	The instruction substantially mirrored Tex. Penal Code §9.31(b)(1); verbatim wording not required if law is accurately stated	No error; instruction correctly expressed the law
4. Cumulative error / due process violation	Cumulative charge defects deprived Allen of accurate presentation of her legal defense	No individual errors (or preserved errors) that could accumulate to constitutional harm	Denied; cumulative-error claim fails

Price v. State, 457 S.W.3d 437 (explaining two-step charge-error review and egregious-harm standard for unpreserved error)
Almanza v. State, 686 S.W.2d 157 (charge-error reversible-harm framework)
Zamora v. State, 411 S.W.3d 504 (defensive issues may be forfeited if not preserved)
Vega v. State, 394 S.W.3d 514 (defendant cannot complain on appeal about unrequested defensive instruction)
Posey v. State, 966 S.W.2d 57 (trial judge not required to give defense instructions absent defendant’s request)
Oursbourn v. State, 259 S.W.3d 159 (same principle on defensive instructions)
Bennett v. State, 235 S.W.3d 241 (defensive instructions must be requested to become applicable law of the case)