Kentavian Juanya Holman v. State, 12-15-00292-CR

On Aug. 31, 2014 an 85‑year‑old woman using an ambulatory device was robbed in her home by an intruder who displayed a knife, threatened her, disabled phones, and took money (including coins).
Neighbor David Hughes observed a person (later identified as Holman in photos) discard a large knife in nearby bushes and pointed police to a residence; police recovered the knife but found no physical evidence linking Holman to the crime.
Holman voluntarily surrendered to police days later accompanied by three alibi witnesses who gave written statements asserting he was elsewhere at the time of the robbery; one alibi statement had dating inconsistencies.
The victim identified Holman in court and (after arrest) from a newspaper photograph; Hughes also identified Holman from photos and in open court. No formal multi‑person photo array was used.
Holman was indicted for aggravated robbery (victim over 65), convicted by a jury, sentenced to 20 years, and filed a motion for new trial which the trial court denied without a hearing. Holman appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Holman)	Held
Sufficiency of the evidence (identity)	Evidence (victim ID, Hughes ID, knife found where Hughes said, circumstantial facts) supports a rational jury finding Holman committed aggravated robbery	Evidence insufficient to prove Holman was the perpetrator; alibi witnesses placed him elsewhere and there was no forensic link	Affirmed: viewing evidence in light most favorable to verdict, a rational jury could find identity beyond a reasonable doubt
Detective testimony about alibi statements / ineffective assistance	Detective summarized investigatory findings and noted inconsistencies; prosecutor relied on scene facts and IDs	Detective’s testimony invaded the jury’s province on credibility; trial counsel’s failure to object was ineffective assistance	Affirmed: issue not preserved by objection; record does not show counsel’s failure was so outrageous to establish ineffective assistance
Denial of hearing on motion for new trial	Motion failed to allege facts not determinable from record or show reasonable grounds for relief; affidavits lacking	Trial court abused discretion by denying hearing on new trial motion	Affirmed: motion’s grounds were either determinable from record or conclusory/unsupported, so no hearing required

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing legal sufficiency of the evidence)
Brooks v. State, 323 S.W.3d 893 (Texas) (Jackson sufficiency is sole standard; deference to jury credibility)
Hooper v. State, 214 S.W.3d 9 (Texas) (circumstantial evidence can establish guilt; combined circumstances probative)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard: deficient performance and prejudice)
Menefield v. State, 363 S.W.3d 591 (Texas) (direct appeal usually inadequate for ineffective assistance claims where record undeveloped)
Hobbs v. State, 298 S.W.3d 193 (Texas) (motion for new trial must be supported by affidavit stating factual basis)
Smith v. State, 286 S.W.3d 333 (Texas) (standards for entitlement to hearing on motion for new trial)
Nava v. State, 415 S.W.3d 289 (Texas) (review of counsel effectiveness; counsel afforded opportunity to explain conduct)
Wallace v. State, 106 S.W.3d 103 (Texas) (trial court’s denial of new‑trial hearing reviewed for abuse of discretion)