Roderick Fountain v. State
401 S.W.3d 344
| Tex. App. | 2013Background
- Fountain was charged with felony murder of Kendrick Jackson; jury found him guilty and life imprisonment issued.
- Indictment alleged injury to a child by striking and an act clearly dangerous to life; jury convicted.
- Defense argued no corpus delicti and no clear-dangerous act or but-for causation; no remains or forensic proof.
- Extrajudicial confessions by Fountain were alleged to corroborate corpus delicti; independent evidence contested.
- Evidence included cell phone records, witness testimony about abuse, and Fountain’s inconsistent statements.
- Court affirmed conviction, finding legally sufficient corpus delicti and causation supporting felony murder
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Corpus delicti sufficiency independent of confessions | Fountain argues corpus delicti not proven | State argues independent evidence corroborates corpus delicti | Corpus delicti proven via circumstantial evidence and corroboration |
| Act clearly dangerous to human life | Fountain contends no clear-dangerous act without expert testimony | State shows striking could be clearly dangerous | Striking proven as act clearly dangerous to human life |
| Causation—but-for link between striking and death | Fountain argues no but-for causation | State shows causation through corroboration and conduct | Evidence supports but-for causation despite other possible causes |
Key Cases Cited
- Fisher v. State, 851 S.W.2d 298 (Tex. Crim. App. 1993) (corpus delicti corroboration standard; independent evidence suffices)
- McDuff v. State, 939 S.W.2d 607 (Tex. Crim. App. 1997) (corpus delicti may be proven by circumstantial evidence)
- Robbins v. State, 717 S.W.2d 348 (Tex. Crim. App. 1986) (concurrent causation framework; 6.04(a) analysis)
- Jackson v. Virginia, 443 U.S. 307 (1980) (standard of review for sufficiency of evidence (due process))