Pridgen, Robert Lynn, PD-0186-15

Background

Defendant Robert Lynn Pridgen (retired prison guard) shot and killed housemate Paul Rohne at Pridgen’s home after waking to Rohne touching his genitals; Pridgen testified Rohne rose with a knife and he shot in self‑defense.
Both men were heavily intoxicated (Rohne BAC .33); officers found Rohne slumped on a loveseat with a knife in his right hand and bruises on his body; no usable prints or DNA on the knife.
Pridgen called 911, remained at the scene, was arrested, tried, and convicted of murder; sentenced to 20 years; court of appeals affirmed.
Trial court excluded ~27 defense exhibits (photos from Rohne’s room/laptop showing bondage/sex‑toy imagery) as irrelevant and character conformity evidence.
Pridgen argues (1) the court of appeals applied an improper, overly permissive sufficiency standard, (2) the appellate court used an impermissible hindsight test for necessity of deadly force, and (3) the trial court erred in excluding the photographs that would corroborate his self‑defense claim.

Issues

Issue	Plaintiff's Argument (Pridgen)	Defendant's Argument (State)	Held
Sufficiency standard for rejecting self‑defense	Court of appeals purported to state Jackson but actually applied a “mere modicum/no‑evidence” test; under proper Jackson review the evidence fails to disprove self‑defense beyond a reasonable doubt (knife equally likely held by Rohne).	Evidence (bruises, lack of struggle, 911 call tone, body position, intoxication, elevated shotgun discharge) permits a rational jury to reject self‑defense beyond a reasonable doubt.	Court of appeals applied standard affording deference to jury; affirmed conviction. (Pridgen asks CCA review.)
Appropriate legal standard for necessity of deadly force	Inquiry must focus on defendant’s reasonable belief at the moment (subjective, not 20/20 hindsight); appellate hindsight undermines proper §9.32 analysis.	Appellate review may consider all evidence; jury may assess credibility and conclude force was not immediately necessary.	Court of appeals framed necessity as a jury question and affirmed rejection of self‑defense.
Admissibility of photos showing Rohne’s simulated sexual violence/bondage	Photos are relevant to show Rohne’s propensity to simulate sexual violence, corroborate Pridgen’s account (knife, intent to sexually assault), rebut planting theory, and are admissible for state of mind/intent—not just character conformity.	Photos do not show Rohne acting as an aggressor on the night, nor use of a knife; they lack a direct/logical connection to the incident and are primarily character evidence.	Trial court excluded exhibits as irrelevant under Rules 401/402 and 404; appellate court held exclusion not an abuse of discretion and affirmed.
Appellate court’s fact‑weighing/credibility role	Appellate opinion impermissibly cherry‑picked evidence and discounted undisputed facts (knife in hand, size disparity, home context, officer training) that support self‑defense; exclusion of photos deprived Pridgen of presenting a complete defense.	Jury as sole factfinder may disbelieve defendant; appellate court must view evidence in light most favorable to verdict; exclusion was within trial court’s discretion.	Appellate court concluded jury could rationally reject self‑defense and that evidentiary exclusion was proper; Pridgen petitions for CCA review.

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (constitutional standard for sufficiency — guilt beyond a reasonable doubt)
In re Winship, 397 U.S. 358 (U.S. 1970) (due process requirement of proof beyond a reasonable doubt)
Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (standards for appellate review when defendant bears burden on affirmative defense)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (limitations on appellate fact‑reweighing; standard for sufficiency review)
Miller v. State, 36 S.W.3d 503 (Tex. Crim. App. 2001) (right to present relevant defense evidence and relevance threshold)
Saxton v. State, 804 S.W.2d 910 (Tex. Crim. App. 1991) (self‑defense as jury question; credibility assessment)
Holmes v. South Carolina, 547 U.S. 319 (U.S. 2006) (constitutional limits on excluding defense evidence)
Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (defendant’s right to present a complete defense)
California v. Trombetta, 467 U.S. 479 (U.S. 1984) (state obligations re: evidence preservation and due process)