Tyler Christian Green v. State, 14-18-00102-CR

Background

Defendant Tyler Christian Green was convicted by a jury of murder; punishment assessed at 50 years’ imprisonment. Appeal to the Fourteenth Court of Appeals affirmed.
Shooting occurred during a drug‑deal meeting in a strip mall parking lot; Green admitted he shot the unarmed decedent five times.
Green claimed self‑defense, testifying the decedent had been threatening, reached toward his feet, and had a violent reputation and tattoos; Green brought a revolver to the meeting and fired before confirming a weapon.
Medical evidence showed close‑contact/back wounds and soot on some wounds; no gun was recovered from the scene.
Trial rulings at issue: (1) exclusion of some communicated‑character evidence (guilt phase), (2) sufficiency of evidence to reject self‑defense, and (3) admission of extraneous‑offense evidence at punishment despite alleged inadequate notice.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Green)	Held
Sufficiency of evidence to reject self‑defense	Evidence (surveillance, wound patterns, post‑offense concealment, inconsistent testimony) supports conviction and rejection of self‑defense.	Self‑defense was reasonable because decedent threatened him, had shown a gun, and made furtive movements.	Affirmed: viewing evidence in the light most favorable to verdict, a rational jury could reject self‑defense.
Exclusion of communicated‑character evidence at guilt phase (burglaries, prior verbal threats, gang membership, prior fights, tattoos)	Exclusion of some specific‑act evidence was within trial court’s discretion under Rules 403/404; ample other evidence of victim’s violence and threats was admitted.	Excluded evidence was admissible as communicated character to show Green’s state of mind and reasonableness of fear.	Trial court did not abuse discretion in excluding burglary evidence; any assumed errors in excluding other items were harmless because defendant presented substantial evidence of the victim’s violence and threats.
Admission of extraneous‑offense and statement evidence at punishment (notice under Art. 37.07)	Evidence (robbery testimony, jail calls, defendant’s statement about wanting to kill) was relevant to sentencing and, where applicable, sufficiently noticed; any notice defects were harmless.	Notice was inadequate for certain extraneous offenses/ statements, producing unfair surprise and violating Art. 37.07.	Any alleged notice errors were nonconstitutional and harmless; defendant waived challenge to racial‑statement evidence by failing to cite record; defendant’s killing statement was an inchoate thought, not an extraneous offense.

Key Cases Cited

Price v. State, 502 S.W.3d 278 (Tex. App.—Houston [14th Dist.] 2016) (general sufficiency standard reference)
Balderas v. State, 517 S.W.3d 756 (Tex. Crim. App. 2016) (standard for reviewing sufficiency—view evidence in light most favorable to verdict)
Morales v. State, 357 S.W.3d 1 (Tex. Crim. App. 2011) (deadly‑force self‑defense statutory standard)
Dearborn v. State, 420 S.W.3d 366 (Tex. App.—Houston [14th Dist.] 2014) (burden shifting for self‑defense evidence)
Zuliani v. State, 97 S.W.3d 589 (Tex. Crim. App. 2003) (initial burden to raise self‑defense)
Saxton v. State, 804 S.W.2d 910 (Tex. Crim. App. 1991) (defensive evidence credibility is for jury; defensive evidence consistent with scene does not make State’s case insufficient)
Braughton v. State, 569 S.W.3d 592 (Tex. Crim. App. 2018) (rejecting self‑defense where facts supported jury’s credibility findings)
Ex parte Miller, 330 S.W.3d 610 (Tex. Crim. App. 2009) (communicated character doctrine—specific acts admissible to show defendant’s state of mind)
Mozon v. State, 991 S.W.2d 841 (Tex. Crim. App. 1999) (limits on character evidence and Rule 403 balancing)
Walters v. State, 247 S.W.3d 204 (Tex. Crim. App. 2007) (harmless‑error analysis where defendant still presented self‑defense)
Hernandez v. State, 176 S.W.3d 821 (Tex. Crim. App. 2005) (notice and surprise analysis for extraneous‑offense evidence)
Roethel v. State, 80 S.W.3d 276 (Tex. App.—Austin 2002) (harm analysis for inadequate notice of extraneous offenses)
Moreno v. State, 858 S.W.2d 453 (Tex. Crim. App. 1993) (inchoate thoughts are not extraneous offenses)