Temple, David Mark
2013 Tex. Crim. App. LEXIS 161
| Tex. Crim. App. | 2013Background
- Appellant David Mark Temple was convicted of murdering his wife Belinda Temple and sentenced to life imprisonment.
- The Fourteenth Court of Appeals affirmed, and this Court granted discretionary review to address sufficiency of the evidence.
- Belinda was eight months pregnant; their son Evan was nearly four years old at the time.
- Evidence showed both favorable and skeptical views of the marriage, with alleged controlling behavior and later affair by Appellant.
- The State argued the totality of circumstances established guilt beyond a reasonable doubt; Temple argued the evidence was insufficient to prove identity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the evidence legally sufficient to prove identity beyond a reasonable doubt? | Temple argues no single fact links him to the murder. | State asserts cumulative circumstantial evidence supports guilt. | Yes; sufficient circumstantial evidence supports guilt beyond a reasonable doubt. |
| Should the court defer to the jury's credibility determinations and inferences? | Temple contends the court misapplied factual-sufficiency review and overruled reasonable inferences. | State argues we rely on legal sufficiency and defer to the jury's credibility determinations. | Yes; appellate review defers to the jury's credibility and reasonable inferences under the legal-sufficiency standard. |
| Do motive and opportunity, though not elements, support guilt? | Temple asserts motive alone cannot prove guilt; insufficient to link him to the crime. | State maintains motive and opportunity bolster guilt via cumulative evidence. | Yes; motive and opportunity, with other circumstantial links, support guilt. |
Key Cases Cited
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (establishes standard for circumstantial-evidence sufficiency; cumulative evidence permitted)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (reaffirms legal-sufficiency standard; not thirteenth juror)
- Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (circumstantial evidence sufficient when collectively supports guilt)
- Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (motive as a significant circumstance indicating guilt)
- Jackson v. Virginia, 443 U.S. 307 (1979) (establishes federal standard for reviewing sufficiency of evidence)
- Adames v. State, 353 S.W.3d 854 (Tex. Crim. App. 2011) (applies modern sufficiency review; weighs all evidence in light of the record)
- Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (rejects outstanding reasonable hypothesis analysis in sufficiency review)
- Turro v. State, 867 S.W.2d 43 (Tex. Crim. App. 1993) (early articulation of standard for circumstantial evidence)