Matthew Ryan Wilson v. State, 391 S.W.3d 131

Wilson was convicted of aggravated assault of his father with a deadly weapon and sentenced to ten years' imprisonment.
The assault began with verbal threats and escalated to physical blows, then Wilson grabbed an eight-pound sledgehammer and approached his father.
The jury heard testimony about Wilson's volatile history and alleged bipolar symptoms, influencing perceptions of his intent.
Terry testified that he feared imminent bodily injury and noted prior violent incidents by Wilson toward his parents.
A sledgehammer was used or displayed in a manner the jury could view as exhibiting a deadly weapon during the assault.
During guilt/innocence deliberations, the jury asked about punishment for a lesser-included offense; the court responded with a punishment range.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence legally sufficient for aggravated assault with a deadly weapon?	Wilson contends mens rea was lacking.	State argues actions and threats show intent to cause imminent injury and display of a deadly weapon.	Yes; evidence supports intent and deadly-weapon use.
Was the sledgehammer a deadly weapon under the five-factor test?	Wilson argues proximity negates deadly-weapon status.	State asserts proximity, threats, weapon size, potential injury, and use support deadly-weapon classification.	Yes; the sledgehammer satisfied the five-factor test.
Did the trial court's response to the jury note about punishment constitute reversible error?	Wilson claims evaluating punishment during guilt phase violated Art. 36.27 and Almanza harm due to improper guidance.	State maintains limited harm and that the court instructed not to consider punishment; error but not reversible.	No reversible harm; error deemed non-egregious.

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for legal-sufficiency review)
Jackson v. Virginia, 443 U.S. 307 (1980) (sufficiency review under federal standard)
Abdnor v. State, 871 S.W.2d 726 (Tex. Crim. App. 1994) (two-step harm analysis for jury-charge errors)
Staggs v. State, 503 S.W.2d 587 (Tex. Crim. App. 1974) (prohibition on considering punishment at guilt stage)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1984) (actual egregious-harm standard for Almanza review)
McCain v. State, 22 S.W.3d 497 (Tex. Crim. App. 2000) (deadly weapon concept under §1.07(a)(17)(B))
Olivas v. State, 203 S.W.3d 341 (Tex. Crim. App. 2006) (whether a victim must perceive threat in assault by threat)
Nash v. State, 175 S.W.3d 427 (Tex. App.—Texarkana 2005) (five-factor test for deadly weapon determination)