Steven Craig Debusk v. State, 05-16-00947-CR

Background

Steven Craig DeBusk pled guilty to murder for the September 11, 2015 beating death of his father, Ronnie (Ron) DeBusk; the trial court sentenced him to 50 years’ imprisonment and made an affirmative deadly-weapon finding.
At punishment the court heard evidence including family testimony about a history of physical abuse by Ron to Steven (childhood belt beatings), escalating conflicts in the household, alcohol use by Steven, and several prior violent incidents by Steven.
On the night of the killing, Steven and Ron argued at a restaurant (Twin Peaks); witnesses described Steven as the aggressor there; later at Ron’s home Ron suffered extensive blunt-force injuries consistent with a prolonged beating and defensive wounds were present; Ron had COPD which contributed to death.
Steven claimed he acted under the immediate influence of sudden passion provoked by Ron’s attack and asserted he ‘‘blacked out’’ and did not remember portions of the incident; he also judicially confessed to the murder in a written plea.
The trial court implicitly rejected Steven’s sudden-passion affirmative defense and accepted his guilty plea; on appeal Steven challenged (1) legal and factual sufficiency of the evidence to reject sudden passion, (2) sufficiency to support murder rather than manslaughter, (3) excessiveness of the 50-year sentence, and (4) the judgment’s plea-bargain entry.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (DeBusk)	Held
Was there legally sufficient evidence to support the trial court’s implied rejection of sudden-passion affirmative defense?	The evidence shows Steven was the aggressor, had motive/predisposition to violence, and the killing was not the product of passion arising from an adequate cause.	Steven argued the provocation and fear from being struck by his father (plus childhood abuse) produced sudden passion that reduced the offense.	Affirmed—more than a scintilla of evidence supported the court’s implied rejection; credibility issues for DeBusk’s testimony justified not crediting it.
Was there factually sufficient evidence to reject sudden passion?	The State relied on totality of evidence (disparity in size/health, prior aggression, prolonged beating and damage to multiple rooms) to show cool reflection was possible.	DeBusk said his testimony and witnesses showed adequate provocation and fear; the verdict was against the great weight of evidence.	Affirmed—the court concluded the verdict was not against the great weight of the evidence; fact finder reasonably disbelieved DeBusk.
Did the evidence support murder (intentional or knowing killing) vs. manslaughter?	The judicial confession and stipulation admitted every element of murder; physical evidence showed repeated, dangerous acts causing death.	DeBusk argued insufficiency to show he intentionally or knowingly caused death (seeking manslaughter).	Affirmed—the judicial confession alone satisfied Article 1.15 and embraced the elements of murder.
Was the 50-year sentence an abuse of discretion violating Penal Code objectives (rehabilitation/prevention)?	Sentence within statutory range; trial court considered evidence and made explicit findings—no abuse of discretion.	DeBusk argued the court refused to consider mitigating factors and thus abused its discretion.	Affirmed—error not preserved and record shows the court considered mitigation; sentence within statutory range.

Key Cases Cited

De Leon v. State, 373 S.W.3d 644 (Tex. App.—San Antonio 2012) (explaining adequate cause and sudden passion standards)
Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (standards for reviewing rejected affirmative defenses; legal/factual sufficiency framework)
Gaona v. State, 498 S.W.3d 706 (Tex. App.—Dallas 2016) (applying sufficiency review to sudden-passion claim)
Dinnery v. State, 592 S.W.2d 343 (Tex. Crim. App. 1979) (judicial confession can alone support conviction on guilty plea)
Menefee v. State, 287 S.W.3d 9 (Tex. Crim. App. 2009) (judicial confession must embrace every element to satisfy Article 1.15)
Ex parte Williams, 703 S.W.2d 674 (Tex. Crim. App. 1986) (historical basis and purpose of Article 1.15)
Aldrich v. State, 104 S.W.3d 890 (Tex. Crim. App. 2003) (trial court must consider evidence presented even if plea remains)