Keondrick Arabian Ali Barlow v. the State of Texas
09-23-00087-CR
Tex. App.Mar 19, 2025Background
- Keondrick Arabian Ali Barlow was convicted by a jury of murdering Lamont Williams, a known drug dealer, in December 2018; the sentence was 80 years’ confinement plus a $10,000 fine.
- Williams was found shot to death in his apartment; his car was found abandoned, and evidence indicated a robbery related to Williams’s illicit drug dealings.
- Barlow voluntarily contacted police multiple times during the investigation but gave inconsistent statements regarding his whereabouts and actions on the night of the murder.
- DNA evidence linked Barlow to several items at the crime scene, including a blood stain, a soda bottle, a condom, and Williams's car.
- Barlow’s statements to police, both written and audio-recorded while in custody, were admitted at trial after the court held a voluntariness hearing.
- The trial court required Barlow, who was indigent, to pay attorney’s fees as part of the judgment.
Issues
| Issue | Barlow's Argument | State's Argument | Held |
|---|---|---|---|
| Voluntariness of Custodial Statements | Statements involuntary due to custodial setting and number of officers present | Statements were voluntary, Barlow was read rights and waived them | Custodial statements were voluntary and admissible |
| Assessment of Attorney’s Fees to Indigent Defendant | Trial court erred by imposing attorney's fees on indigent defendant | Conceded error; agrees with Barlow | Error; fees stricken from judgment |
Key Cases Cited
- Lerma v. State, 543 S.W.3d 184 (Tex. Crim. App. 2018) (standard for reviewing trial court’s suppression rulings)
- State v. Lujan, 634 S.W.3d 862 (Tex. Crim. App. 2021) (deference to trial court factual findings)
- Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (trial court as trier of fact on credibility in voluntariness hearings)
- Davis v. State, 313 S.W.3d 317 (Tex. Crim. App. 2010) (voluntariness standard for custodial confessions)
- Garza v. State, 213 S.W.3d 338 (Tex. Crim. App. 2007) (deference to trial court’s credibility determinations)
- Cole v. State, 490 S.W.3d 918 (Tex. Crim. App. 2016) (standard for de novo review where appropriate)
- Roberts v. State, 327 S.W.3d 880 (Tex. App.—Beaumont 2010) (improper to assess attorney’s fees to indigent criminal defendant without showing changed circumstances)