Stanton Wayne Yates v. State
06-16-00011-CR
| Tex. App. | Nov 9, 2016Background
- Stanton Wayne Yates was tried for five counts of engaging in organized criminal activity; the jury convicted him of four OCA counts and the lesser-included offense of burglary of a habitation for the Campbell home entry on December 31, 2014.
- Brenda Campbell returned home to find a forced door, a missing Glock 9mm, jewelry, a silver dollar, and cash; a walkie-talkie was found in the drawer.
- Neighbor Vickers saw an older blue SUV at the Campbell residence that left and quickly returned the same afternoon.
- Perry Yates (Stanton’s brother) testified as an accomplice that he drove Stanton to multiple Hopkins County burglaries, they used radios/cell phones, and Stanton sold stolen jewelry to Archie Anderson.
- Business records and other victims’ testimony linked Stanton to sales of jewelry and guns; a Collin County stop of Perry and Stanton yielded jewelry, cash, and a pistol similar to stolen items.
- The jury convicted Stanton of burglary; on appeal he argued legal insufficiency of the evidence for the burglary conviction. The court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal sufficiency of evidence for burglary of a habitation | State: Non-accomplice evidence (victim testimony, neighbor, business records, items recovered at arrest, extraneous offenses) tends to connect Yates to the Campbell burglary. | Yates: Evidence insufficient; State relied heavily on accomplice (Perry) testimony and did not directly link Stanton to Campbell burglary. | Affirmed: Viewing evidence in the light most favorable to verdict, there was sufficient non-accomplice corroboration to connect Yates to the offense. |
Key Cases Cited
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson standard applied under Texas law for sufficiency review)
- Jackson v. Virginia, 443 U.S. 307 (1979) (legal-sufficiency standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (definition of hypothetically correct jury charge for sufficiency review)
- Gill v. State, 873 S.W.2d 45 (Tex. Crim. App. 1994) (accomplice-witness rule: need only some non-accomplice evidence tending to connect accused)
- Castillo v. State, 221 S.W.3d 689 (Tex. Crim. App. 2007) (procedure for evaluating corroboration when accomplice testimony is admitted)