William Gerard Palmer v. State, 05-14-00671-CR

Background

On Jan 26, 2012, William Gerard Palmer went to his estranged wife’s in-laws’ home, stabbed and killed his wife, father-in-law, and mother-in-law; a child survived and called 911. Palmer returned home, cleaned up, and was arrested shortly thereafter.
Palmer pleaded not guilty but admitted the killings; he did not assert legal insanity and instead argued diminished capacity negated the specific intent required for capital murder.
At a pretrial hearing, the court allowed two defense experts (Drs. McGarrahan and Lipman) but excluded testimony from Dr. Kristi Compton as unhelpful/confusing because she could not definitively say Palmer lacked intent.
The jury convicted Palmer of capital murder; the court assessed punishment as life imprisonment without parole (jury decision), but the written judgment initially omitted the "without parole" language.
Palmer appealed, arguing the exclusion of Dr. Compton’s testimony violated his rights and that the court erred in refusing a manslaughter lesser-included instruction; the State cross-appealed the sentencing language in the judgment.

Issues

Issue	Plaintiff's Argument (Palmer)	Defendant's Argument (State)	Held
Admissibility of Dr. Compton’s expert testimony on diminished capacity	Dr. Compton was qualified; her testimony about Palmer’s mental disorders and medication effects would help negate intent and should have been admitted	Testimony did not truly negate mens rea; Compton could not opine that Palmer lacked intent and would confuse/jury and was properly excluded	Exclusion affirmed — court did not abuse discretion because her proffer did not negate the required mens rea
Right to present defense / due process from exclusion of expert testimony	Exclusion violated right to present a defense and right to jury trial	Court properly exercised discretion; other experts testified and Compton’s proffer added no legally probative link to intent	Denied — no due process violation demonstrated; testimony wouldn’t have negated intent
Failure to give manslaughter lesser-included instruction	Evidence of diminished capacity and expert testimony warranted a manslaughter instruction (reckless mens rea)	No affirmative evidence showed only reckless (and no intent); experts did not link their opinions to a reckless mental state at the time	Denied — no evidence from which a rational jury could conclude Palmer acted only recklessly
State cross-issue: discrepancy between oral sentence and written judgment	N/A (State asked correction)	Written judgment omitted "without the possibility of parole," conflicting with oral pronouncement	Sustained — judgment modified to reflect life imprisonment without possibility of parole (oral pronouncement controls)

Key Cases Cited

Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (evidence of mental condition admissible only if it truly negates required mens rea)
Jackson v. State, 160 S.W.3d 568 (Tex. Crim. App. 2005) (mental-condition evidence inadmissible to show lack of capacity except insanity defenses)
Rodgers v. State, 205 S.W.3d 525 (Tex. Crim. App. 2006) (criteria for admissibility of expert testimony)
Mays v. State, 318 S.W.3d 368 (Tex. Crim. App. 2010) (excluded mental-health evidence insufficient where it did not negate specific intent)
Woods v. State, 306 S.W.3d 905 (Tex. App.—Beaumont 2010) (mental-condition testimony not probative of intent when not tied to defendant’s culpable mental state)
Cavazos v. State, 382 S.W.3d 377 (Tex. Crim. App. 2012) (Aguilar/Rousseau two-step test for lesser-included offense instructions)
Price v. State, 457 S.W.3d 437 (Tex. Crim. App. 2015) (analysis for determining jury charge error)
Thompson v. State, 108 S.W.3d 287 (Tex. Crim. App. 2003) (oral pronouncement of sentence controls over conflicting written judgment)
Threadgill v. State, 146 S.W.3d 654 (Tex. Crim. App. 2004) (standard of review for submitting or denying lesser-included instructions)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (harm analysis framework for jury charge error)