Williams, Treyvon Raymond
PD-0183-15
| Tex. App. | Feb 18, 2015Background
- Williams was indicted for murder in Fort Bend County, Texas.
- He pled not guilty on June 4, 2013 and proceeded to trial.
- A jury convicted him and imposed a 70-year sentence.
- Appellant argued the evidence supported self-defense and defense of a third person.
- First Court of Appeals affirmed the conviction (Dec. 16, 2014); rehearing denied Jan. 15, 2015.
- Appellant seeks discretionary review raising two grounds about sufficiency and lesser-included offenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for self-defense | Williams argues no rational jury could find guilt beyond reasonable doubt. | State contends sufficient evidence supported guilt beyond a reasonable doubt. | Affirmed; rational jury could reject self-defense evidence. |
| Lesser-included offenses instructions | Williams requests instructions on manslaughter, criminally negligent homicide, deadly conduct. | State argues no entitlement to lesser offenses given self-defense evidence. | Affirmed; no error in denying lesser-included instructions. |
Key Cases Cited
- Cavazos v. State, 382 S.W.3d 377 (Tex. Crim. App. 2012) (two-prong test for lesser-included offenses; some evidence required)
- Saxton v. State, 804 S.W.2d 910 (Tex. Crim. App. 1991) (self-defense as a jury issue; implicit finding against self-defense when guilty)
- Skinner v. State, 956 S.W.2d 532 (Tex. Crim. App. 1997) (evidence sufficiency related to lesser offenses)
- Sweed v. State, 351 S.W.3d 63 (Tex. Crim. App. 2011) (some evidence supporting lesser offenses must exist)