Rickey Donell Williamson v. State, 589 S.W.3d 292

Appellant Rickey Donell Williamson was convicted of aggravated assault with a deadly weapon after using a box‑cutting knife to inflict a deep facial gash on Jaime Ramirez; sentence: 40 years.
Incident: Ramirez struck Williamson twice, Williamson went to one knee, later rose and cut Ramirez; Ramirez suffered a serious laceration requiring surgery.
Williamson claimed he acted in self‑defense; police found Williamson later holding an open box‑cutting knife and recorded him initially denying involvement and denying injuries.
Before trial, the court ruled two prior family‑violence assault convictions admissible under Tex. R. Evid. 609 if Williamson testified; Williamson then disclosed those convictions on direct examination.
On appeal Williamson argued (1) the trial court misapplied Rule 609/Theus factors in admitting his prior convictions and (2) the evidence was insufficient to disprove his self‑defense claim.
The court affirmed: (1) Williamson waived his Rule 609 complaint by eliciting the convictions on direct exam; (2) sufficient evidence supported the jury’s rejection of self‑defense.

Issue	Williamson's Argument	State's Argument	Held
Admissibility of prior family‑violence convictions under Tex. R. Evid. 609	Trial court misapplied Theus balancing; convictions should not have been admissible	Waiver: Williamson elicited the convictions on direct exam after court ruled they would be admissible	Waived — defendant who preemptively introduces convictions on direct examination may not complain on appeal (affirmed)
Sufficiency of evidence to reject self‑defense	No reasonable jury could reject self‑defense given Williamson was dazed and reasonably feared further harm	Jury could disbelieve Williamson based on Ramirez/Sparks testimony, medical severity, Williamson’s recorded denials, and lack of injuries on Williamson	Sufficient — viewing evidence in prosecution’s favor, a rational jury could find guilt and reject self‑defense (affirmed)

Ohler v. United States, 529 U.S. 753 (defendant who introduces a prior conviction on direct examination waives appellate challenge to its admission)
Theus v. State, 845 S.W.2d 874 (sets nonexclusive factors for weighing probative value versus prejudice under Rule 609)
Brooks v. State, 323 S.W.3d 893 (describes Texas legal‑sufficiency review under Jackson)
Jackson v. Virginia, 443 U.S. 307 (standard for constitutional sufficiency of the evidence)
Saxton v. State, 804 S.W.2d 910 (explains burdens and review when self‑defense is raised)
Lancon v. State, 253 S.W.3d 699 (deference to jury determinations of witness credibility)