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Randolph Juarez McClinton v. the State of Texas
01-20-00779-CR
| Tex. App. | Sep 14, 2021
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Background

  • Appellant Randolph Juarez McClinton pleaded guilty to first‑degree murder and waived a jury; the punishment hearing addressed whether the killing occurred under "sudden passion."
  • Victim T. Weatherall saw flirtatious Facebook messages between McClinton and Weatherall’s partner, Green; Weatherall (using Green’s account at times) sent threatening messages and later arranged a meeting purporting to buy marijuana.
  • At the first encounter Weatherall approached McClinton and asked to fight; McClinton displayed a gun and Green and Weatherall walked away.
  • McClinton then drove up alongside Weatherall, threatened him while pointing a gun, and fired one shot that killed Weatherall; Green witnessed the events.
  • McClinton told police he "reacted" because he feared for his life and expressed remorse; the trial court rejected his sudden‑passion claim and sentenced him to 25 years and a $10,000 fine.
  • On appeal McClinton argued the evidence was legally and factually insufficient to support the trial court’s finding that the killing was not committed under sudden passion.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether evidence is legally and factually sufficient to sustain the trial court’s finding that McClinton did not act under "sudden passion" arising from adequate cause State: Evidence shows McClinton precipitated the fatal second encounter, threatened Weatherall, and was the aggressor—so sudden passion was not proved McClinton: Weatherall provoked and threatened him (via the set‑up and confrontation), placing him in fear of his life; thus the record is insufficient to disprove sudden passion Affirmed: Both legal and factual sufficiency support the trial court’s negative finding on sudden passion; sentence and fine affirmed

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (sets the standard for appellate review of sufficiency of the evidence)
  • Brooks v. State, 323 S.W.3d 893 (discusses standards for reviewing sufficiency where defendant bears burden)
  • Matlock v. State, 392 S.W.3d 662 (explains differing standards when defendant bears burden of proof)
  • McKinney v. State, 179 S.W.3d 565 (defines limits of adequate cause and sudden passion)
  • Moncivais v. State, 425 S.W.3d 403 (outlines civil legal sufficiency two‑step test for affirmative defenses)
  • Meraz v. State, 785 S.W.2d 146 (sets forth Meraz factual‑sufficiency standard for defendant‑burden issues)
  • Cornett v. State, 405 S.W.3d 752 (holds a defendant cannot rely on a cause of his own making to claim sudden passion)
  • Wooten v. State, 400 S.W.3d 601 (explains that ordinary insults/anger are insufficient for adequate cause)
Read the full case

Case Details

Case Name: Randolph Juarez McClinton v. the State of Texas
Court Name: Court of Appeals of Texas
Date Published: Sep 14, 2021
Docket Number: 01-20-00779-CR
Court Abbreviation: Tex. App.