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