Raul Salazar Martinez v. the State of Texas, 02-19-00428-CR

Appellant Raul Salazar Martinez was convicted by a jury of murder with a firearm; sentence: 70 years’ confinement and a $10,000 fine.
Video surveillance showed Martinez pull a pistol from his waistband, confront the victim (Ben Williams), force him back, then deliberately raise and shoot him; victim fell instantly.
Martinez testified he feared Williams, claimed the shooting was accidental during a struggle, and later disposed of the gun and fled to Mexico.
Autopsy: bullet entered beneath the lower lip, traversed the mouth and severed the spinal cord; gunpowder stippling indicated intermediate range.
Martinez raised three appellate issues: (1) trial court erred by refusing a jury instruction on evaluating expert testimony; (2) trial court improperly excluded evidence of the decedent’s violent propensity; (3) evidence was insufficient to support conviction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Martinez)	Held
Sufficiency of the evidence	Evidence (video + autopsy) supports intentional murder and deliberate-act paragraph of indictment	Evidence was insufficient; shot was accidental in struggle; testimony showed fear and lack of intent	Affirmed — viewing evidence in light most favorable to verdict, a rational juror could find guilt beyond a reasonable doubt (Jackson standard)
Requested jury instruction on expert testimony	General charge already instructs jurors to judge credibility and weight; special instruction not required	Requested a specific instruction explaining how to evaluate expert opinions; argued other jurisdictions use such an instruction	Affirmed — trial court properly refused; requested instruction not grounded in penal code, covered by general charge, and would impermissibly focus on a type of evidence (Walters)
Exclusion of evidence of victim’s propensity for violence	Evidence was inadmissible on the proffered ground (Rule 613 not opened); State objected	Sought to admit prior statements of victim’s girlfriend to show Williams’s violent history or bias; argued admissibility under Rules 401, 402, 403, 404(b)(2) on appeal	Affirmed — error not preserved: Martinez relied on Rule 613 at trial but raised different rules on appeal; appellate argument must comport with trial-court argument (Reyna)

Jackson v. Virginia, 443 U.S. 307 (establishes the beyond-a-reasonable-doubt sufficiency standard)
Queeman v. State, 520 S.W.3d 616 (discusses appellate sufficiency review and deference to factfinder)
Murray v. State, 457 S.W.3d 446 (cumulative-evidence approach in sufficiency review)
Villa v. State, 514 S.W.3d 227 (courts must consider cumulative force of evidence)
Kirsch v. State, 357 S.W.3d 645 (procedures for reviewing jury-charge error)
Walters v. State, 247 S.W.3d 204 (defendant not entitled to instruction that focuses jury on a specific type of evidence)
Reyna v. State, 168 S.W.3d 173 (preservation rule: trial argument must be specific and appellate argument must comport with trial argument)
Vinson v. State, 252 S.W.3d 336 (proponent bears burden to establish admissibility when evidence is objected to)
Molina v. State, 450 S.W.3d 540 (failure to present a particular admissibility theory at trial forfeits that theory on appeal)