Sandrella Lakay Hill A/K/A Sandrella Spraglin v. State of Texas
426 S.W.3d 868
| Tex. App. | 2014Background
- Appellant was convicted of aggravated robbery and sentenced to 20 years' confinement and a $5,000 fine, with two prior felony-enhancement allegations found true.
- The conviction was challenged due to a harmful constitutional error: defense counsel was precluded from asking a proper voir dire question concerning the full range of punishment.
- The State introduced eyewitness testimony from Spain detailing entry by force, stabbing with scissors, being struck with a fan, and property loss including a stolen television.
- Appellant and co-defendant Richardson offered alternate accounts denying involvement in a weapon use or stabbing, and claiming a different sequence of events in Spain’s apartment.
- The appellate court affirmed sufficiency of the evidence for guilt but reversed and remanded for a new trial due to the voir dire error regarding punishment range.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether voir dire restriction on punishment range was constitutional error | Hill | State | Constitutional error; require Rule 44.2(a) review |
| Whether the voir dire error affected substantial rights or required reversal | Hill | State | Harmless error not shown; sustain due to potential impact on jurors 10–12 |
| Sufficiency of the evidence to prove aggravated robbery | State | Hill | Sufficiency supported; rational jury could find use of a deadly weapon and intent part of robbery |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for sufficiency of the evidence)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson standard applied in Texas)
- Polk v. State, 337 S.W.3d 286 (Tex. App.—Eastland 2010) (sufficiency and standard of review guidance)
- Cardenas v. State, 325 S.W.3d 179 (Tex. Crim. App. 2010) (jury must be able to consider full range of punishment; for-cause challenges)
- Martinez v. State, 588 S.W.2d 954 (Tex. Crim. App. 1979) (refusal to allow voir dire on full punishment range analysis context)
- Plair v. State, 279 S.W.2d 267 (Tex. Crim. App. 1925) (voir dire and evaluation of range of punishment; historically cited)
- Carlis v. State, 51 S.W.2d 729 (Tex. Crim. App. 1932) (insufficient voir dire questions; per se analyses later overruled)
- Dowthitt v. State, 931 S.W.2d 244 (Tex. Crim. App. 1996) (harmless error framework in appellate review)
- Jones v. State, 223 S.W.3d 379 (Tex. Crim. App. 2007) (impartial jury; voir dire and challenges for cause)
- Wappler v. State, 183 S.W.3d 765 (Tex. App.—Houston [1st Dist.] 2005) (harmlessness and factors for assessing voir dire impact)