Racheal Meachell Mathews v. State, 05-14-00884-CR

On June 3, 2013, Mathews’s 10‑year‑old daughter, D.B., fled naked to a neighbor with bruises and welts after Mathews had struck her (admitted: 40–60 belt strikes), ordered her to remove clothing, and police found long strips of used duct tape in Mathews’s trash. D.B. did not testify.
Mathews pleaded guilty to injury to a child (third‑degree felony) without a plea bargain; the trial court assessed an eight‑year prison sentence.
At punishment Mathews testified she had been stressed, spanked D.B. for behavioral problems, lost control, and later regretted the conduct; she argued termination of parental rights and other civil sanctions were sufficient punishment.
The State presented evidence of D.B.’s serious injuries and fear of Mathews and introduced Mathews’s post‑offense conduct (violating a court order to contact D.B., contempt).
Mathews filed (but apparently did not present) a motion for new trial claiming excessive punishment; she contended on appeal the sentence was cruel and unusual and the court failed to consider the full punishment range.

Issue	Mathews’s Argument	State’s Argument	Held
Whether the eight‑year sentence is cruel and unusual/grossly disproportionate	Eight years is excessive given lack of prior convictions, remorse, and loss of parental rights	Sentence is within statutory range and supported by severity of injuries and facts	Not unconstitutional; complaint not preserved and sentence not grossly disproportionate
Whether trial court denied due process by refusing closing argument and not considering full range of punishment (community supervision)	Trial judge refused closing argument and did not acknowledge consideration of community supervision	Court heard extensive punishment evidence, questioned witnesses, and there is no indication it refused to consider full range	No due process violation; presumption that court considered full range not overcome

Curry v. State, 910 S.W.2d 490 (Tex. Crim. App. 1995) (preservation requirement for Eighth Amendment challenge)
Rhoades v. State, 934 S.W.2d 113 (Tex. Crim. App. 1996) (state‑constitutional cruel and unusual claim must be preserved)
Barrow v. State, 207 S.W.3d 377 (Tex. Crim. App. 2006) (punishment within statutory range generally not excessive)
Lockyer v. Andrade, 538 U.S. 63 (2003) (gross disproportionality principle is reserved for exceedingly rare cases)
Solem v. Helm, 463 U.S. 277 (1983) (framework for proportionality review)
Grado v. State, 445 S.W.3d 736 (Tex. Crim. App. 2014) (right to consideration of full punishment range is waivable‑only; may be raised on appeal)
Brumit v. State, 206 S.W.3d 639 (Tex. Crim. App. 2006) (presumption of judicial impartiality; indicators showing court considered full range)