Standifer, Ronny Joe, PD-1339-15

Defendant Ronny Joe Standifer was convicted by a jury of aggravated assault causing serious bodily injury; sentence: life imprisonment and $10,000 fine. Appeal followed.
The alleged victim had died before trial, so the State’s case relied largely on circumstantial evidence (medical testimony, photos, police observations, and defendant’s statements).
During voir dire the prosecutor asked the panel how the State could prove the case without the victim and what evidence jurors would want to see (e.g., medical testimony, photos, DNA, prior incidents).
Defense counsel objected during voir dire, calling the questioning an improper commitment and asking the court to prohibit that line of questioning; the trial court overruled.
On appeal to the Tenth Court of Appeals the sole issue was whether error in the voir dire was preserved; the court held any error was not preserved. This petition seeks discretionary review, arguing the objection did preserve the complaint.

Issue	Plaintiff's Argument (Standifer)	Defendant's Argument (State)	Held (Tenth Court of Appeals)
Whether voir dire questions asking jurors what evidence they would need without a victim constituted improper juror commitment	The questioning asked jurors to set decision-making parameters and improperly primed them to accept circumstantial proof; it was an improper commitment	The State contends voir dire questions exploring whether jurors could convict without the victim and what evidence they would rely on were proper inquiry into juror views	The court of appeals did not reach the merits; it held any error was not preserved for appeal (complaint forfeited)
Whether defense objection during voir dire sufficiently preserved error under Tex. R. App. P. 33.1 and Draughon	Standifer argues his contemporaneous objection (“improper commitment”) apprised the court of the complaint and the adverse ruling was authoritative enough to obviate further objection	The State (and court of appeals) treated the record as showing insufficient preservation — implying further objections or a more specific ground were required	Tenth Court of Appeals: error (if any) not preserved; appellate review barred by preservation rule

Allridge v. State, 850 S.W.2d 471 (Tex.Crim.App. 1991) (prohibits binding jurors to verdicts via commitment questions)
Draughon v. State, 831 S.W.2d 331 (Tex.Crim.App. 1992) (contemporaneous objection must apprize trial judge of complaint; authoritative ruling can obviate further objection)
Sells v. State, 121 S.W.3d 748 (Tex.Crim.App. 2003) (trial court has broad discretion over voir dire; improper commitment questions are reviewable for abuse of discretion)
Barajas v. State, 93 S.W.3d 36 (Tex.Crim.App. 2002) (scope of proper voir dire inquiry and deference to trial court's management of jury selection)
Standefer v. State, 59 S.W.3d 177 (Tex.Crim.App. 2001) (open-ended voir dire can be improper if it asks jurors to set hypothetical parameters for decision-making)