Matthew Jacob Contreras v. State, 01-15-00337-CR

Matthew Contreras stabbed and killed Erick Bejarano multiple times with a chef’s knife after an altercation at his uncle Lazaros’s house; police found Bejarano dead and Contreras with blood on his body and clothes.
Contreras claimed he acted in self-defense and to protect family members because Bejarano had allegedly fired a gun and boasted of gang (Mara 18th Street) membership; he testified he blacked out during the attack.
Witness testimony conflicted: some testified a gunshot was heard and that Contreras stabbed Bejarano repeatedly; others did not hear a gunshot; one witness hid a gun the night of the incident.
Forensic evidence showed Bejarano had 35 sharp-force wounds and had not recently fired a gun; the knife and Contreras’s clothing bore blood consistent with the killing.
Contreras was convicted of murder with a deadly weapon and sentenced to 40 years; he appealed arguing (1) insufficient evidence to disprove his self-defense claim and (2) improper exclusion of evidence tying Bejarano to a gang.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to disprove self-defense	State: Evidence and witness testimony rebut self-defense; Contreras’s credibility questionable; prosecution need only persuade beyond a reasonable doubt.	Contreras: His testimony and some testimony (e.g., R.R. fled) support self-defense; State failed to disprove self-defense beyond a reasonable doubt.	Affirmed: Evidence sufficient; jury could reject Contreras’s self-defense claim based on credibility, injuries, and forensic evidence.
Exclusion of gang-related evidence	State: Exclusion not shown to be error because defendant failed to make offers of proof; record lacks substance of excluded materials.	Contreras: Trial court improperly excluded gang-tracker records, an article, and testimony about Bejarano’s gang ties which were relevant to his fear.	Affirmed (waiver): Error not preserved because Contreras did not make offers of proof or otherwise show the substance of the excluded evidence.

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (deference to jury on credibility and weighing evidence)
Zuliani v. State, 97 S.W.3d 589 (Tex. Crim. App. 2003) (defendant must produce some evidence of justification; State bears persuasion beyond reasonable doubt)
Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (circumstantial-evidence sufficiency standard applies equally)
McClesky v. State, 224 S.W.3d 405 (Tex. App.—Houston [1st Dist.] 2006) (clarifies State’s burden after defendant raises self-defense)
Hernandez v. State, 309 S.W.3d 661 (Tex. App.—Houston [14th Dist.] 2010) (discusses burden of persuasion when justification raised)
Holmes v. State, 323 S.W.3d 163 (Tex. Crim. App. 2009) (explains offer-of-proof requirement to preserve evidentiary exclusion error)