Louis, Cory Don, 393 S.W.3d 246

Louis was convicted of capital murder for the death of his girlfriend's two-year-old son; the death occurred after disciplining the children with a belt following a mess in the home.
The State did not seek the death penalty, so Louis received a life sentence; the mother testified and faced related charges, with her guilty plea and testimony implicating Louis.
The jury was instructed on multiple lesser-included offenses and included a transferred-intent provision in the charge, along with language about criminal responsibility when the result differs only by offense charged.
Louis requested a mistake-of-fact instruction, which the trial court denied; the Court of Appeals reversed on sufficiency and found error in the jury charge, remanding for new trial on lesser offenses.
The State challenged the Court of Appeals on sufficiency, error in the mistake-of-fact instruction, and whether any charge error was harmless; the Supreme Court granted review on these grounds.
The Court held that the Court of Appeals correctly concluded insufficiency of evidence for capital murder, reversed on grounds related to mistake-of-fact, and affirmed the Court of Appeals on harm, leading to an affirmance of the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the evidence legally sufficient to prove capital murder?	Louis lacked intent to kill; the evidence supports only discipline, not probable death.	State argues the evidence shows intent or knowledge that death was certain or substantially certain to occur.	No; evidence insufficient to prove intentional/knowingly caused death beyond reasonable doubt.
Was a mistake-of-fact instruction required or appropriate?	Louis entitled to instruction under Thompson and related doctrine because transferred-intent logic applied to multiple offenses.	State argues Thompson was limited and mistake-of-fact not applicable to all offenses here.	Yes; Louis was entitled to the requested mistake-of-fact instruction; grounds three and four and five overruled.
Was the failure to give a mistake-of-fact instruction harmful?	Lack of instruction deprived Louis of presenting defense and argue lack of requisite mens rea; Almanza harm standard applies.	Some harm but denied entirely or deemed harmless because transferred-intent instruction exists.	Some harm established; reversal on harm and instruction grounds; verdict affirmed as to overall judgment with these issues.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard: reasonable doubt from evidence viewed in light most favorable to verdict)
Gear v. State, 340 S.W.3d 743 (Tex. Crim. App. 2011) (reaffirms Jackson sufficiency standard and weight/credibility deferment to jury)
Thompson v. State, 236 S.W.3d 787 (Tex. Crim. App. 2007) (mistake-of-fact instruction required when transferred-intent applied; extends to similar contexts)
Robles v. State, 273 S.W.3d 322 (Tex. Crim. App. 2008) (capital murder as a result-of-conduct offense; informs transfer considerations)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (harm standard for Almanza review of jury-charge errors)
Wirth v. State, 361 S.W.3d 694 (Tex. Crim. App. 2012) (deference to jury credibility determinations; proper sufficiency review doctrine)