Roy Leslie Crayton v. State
03-15-00038-CR
| Tex. App. | Jul 21, 2015Background
- Crayton challenged in Third Court of Appeals, appeal from misdemeanor conviction for interfering with an emergency call under Tex. Penal Code § 42.062(a).
- Trial in Burnet County culminated in a guilty verdict Oct 13, 2014, with probation and fines approved as punishment.
- Incident stemmed from a May 30, 2013 dispute at a Granite Shoals residence; Martin reported being threatened and Crayton claimed eviction-related tension.
- Evidence showed Crayton allegedly pushed Martin with his belly and took the telephone from Martin to prevent calling police; Martin left unharmed.
- Crayton contends the record lacks fear of imminent assault and lacks imminent-threat circumstances; issues framed as sufficiency challenges on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence shows an emergency call under §42.062(d) | Crayton argues Martin was not in fear of imminent assault. | State contends the evidence, viewed in the light most favorable to the verdict, shows fear of imminent assault. | Evidence supports an emergency and interference beyond a reasonable doubt |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for legal sufficiency review; no modicum of evidence rule)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson v. Virginia standard applied to each element)
- Garcia v. State, 367 S.W.3d 683 (Tex. Crim. App. 2012) (imminent threat and credibility considerations in sufficiency)