Paul Cody Teague v. the State of Texas, 07-20-00074-CR

Victim was recruited to appellant Paul Teague’s trailer under the pretense of work/housing and then detained after refusing to pay alleged debt for broken headphones.
Over several days Teague restrained, beat, choked, chained, and repeatedly sexually assaulted Victim; another man (James Washburn) anally penetrated Victim with a dildo causing a colon perforation (serious bodily injury).
Victim was eventually released/dropped off at a medical facility and disclosed multiple rapes and beatings; medical exam corroborated deep anal penetration and a dangerous injury.
Police arrested Teague; he was indicted on three counts of aggravated sexual assault and one count of aggravated kidnapping, with a prior aggravated-sexual-assault enhancement.
A jury convicted Teague of one count of aggravated sexual assault (Count I), two counts of sexual assault (lesser-included offenses), and aggravated kidnapping; Teague pled true to the enhancement and received life sentences.
On appeal Teague challenged (1) sufficiency of evidence that, as a party, he intended Washburn to cause serious bodily injury (aggravated sexual assault), and (2) sufficiency of evidence that oral penetration (Count III) was without Victim’s consent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Teague, as a party, must have intended Washburn to cause serious bodily injury for aggravated sexual assault (Count I).	State: Teague intended to promote/assist the sexual assault; transferred intent and foreseeability make him liable for resulting serious bodily injury.	Teague: Party-liability intent must extend to the aggravating result (serious bodily injury); Nava suggests intent to cause the fatal/result element is required.	Court: Affirmed conviction. Applied transferred-intent and foreseeability; Teague’s participation and violent acts made serious bodily injury a foreseeable consequence, satisfying party liability for aggravated sexual assault.
Whether evidence proves lack of consent for oral penetration (Count III).	State: Victim was forced/coerced — Teague used physical force, detained her, and refused to let her leave; subsequent acts were nonconsensual.	Teague: Victim’s initial sexual act (including oral sex) may have been consensual because she testified she complied when promised a ride home.	Court: Affirmed conviction. Jury could reasonably find initial act coerced (shoved, detained, threatened) and all subsequent acts nonconsensual; evidence sufficient.

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
Brooks v. State, 323 S.W.3d 893 (appellate deference to jury credibility/weight under Jackson)
Malik v. State, 953 S.W.2d 234 (measure sufficiency against elements defined by hypothetically correct jury charge)
Rodriguez v. State, 538 S.W.3d 623 (no separate mens rea required for aggravating serious-bodily-injury element where statute is silent)
Nava v. State, 415 S.W.3d 289 (party-liability can require intent as to the fatal/result element in felony-murder context)
Metcalf v. State, 597 S.W.3d 847 (discusses transferred intent doctrine under Penal Code § 6.04(b)(1))
Curtis v. State, 573 S.W.2d 219 (collateral/unintended crimes may be charged against all participants when foreseeable and probable)
Nisbett v. State, 552 S.W.3d 244 (culpable mental state may be inferred from the nature and extent of victim’s injuries)