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Wingfield, Anthony Bernard
PD-1618-15
| Tex. App. | Dec 15, 2015
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Background

  • Wingfield was indicted for assault causing bodily injury to a person he had a dating relationship with (Angela Dickerson) with an enhancement alleging a prior conviction for a family-violence-related offense; he pleaded not guilty.
  • The State offered a two-year TDCJ plea deal in open court available until October 10, 2013; the prosecutor later withdrew the offer before the defendant entered the plea.
  • The alleged victim, Angela Dickerson, gave multiple inconsistent accounts (including admissions that she struck Wingfield first and that versions differed in written statements) and executed an affidavit of non‑prosecution.
  • The defense moved for directed verdict and argued the State’s exhibit proving the prior conviction showed “no finding of family violence,” undermining the enhancement required for the felony family‑violence charge.
  • The trial court denied the motion to quash (vindictive prosecution) and denied the directed verdict; Wingfield was convicted and sentenced to 45 years. The Seventh Court of Appeals affirmed; Wingfield petitioned the Court of Criminal Appeals for discretionary review.

Issues

Issue Plaintiff's Argument (Wingfield) Defendant's Argument (State) Held
Sufficiency of evidence that Wingfield "struck" victim causing bodily injury Evidence is insufficient because the victim gave multiple inconsistent versions and other witnesses did not see an assault; a rational juror could not find guilt beyond a reasonable doubt The record contains testimony that Wingfield punched the victim and other supporting evidence sufficient for a jury to convict Trial court denied directed verdict; conviction affirmed on appeal (petitioner seeks review)
Sufficiency of proof that prior conviction was a qualifying family‑violence offense (enhancement) State’s exhibit establishing the prior conviction shows "no finding of family violence," so the enhancement element is unproven and felony conviction is unsupported The State contends the prior conviction suffices to support the enhancement as alleged in the indictment Trial court rejected defense challenge; conviction and enhancement stood on appeal (issue raised for review)
Vindictive prosecution / breach of plea offer The State promised the two‑year plea would remain open until Oct 10; Wingfield accepted before that date; the State’s withdrawal was vindictive and violated due process The State can withdraw offers prior to court approval; plea offers are not binding until accepted and approved by the court Trial court denied motion to quash; appellate courts did not grant relief (petitioner seeks review)

Key Cases Cited

  • Edison v. State, 235 S.W.3d 303 (Tex. App. 2008) (indictment allegations descriptive of essential elements)
  • Mitchell v. State, 102 S.W.3d 773 (Tex. App. 2003) (elements and proof requirements)
  • Weaver v. State, 551 S.W.2d 419 (Tex. Crim. App. 1977) (indictment and element pleading)
  • Franklin v. State, 659 S.W.2d 831 (Tex. Crim. App. 1983) (elemental pleading analysis)
  • Taylor v. State, 637 S.W.2d 929 (Tex. Crim. App. 1982) (indictment must allege legally essential facts)
  • Sieffert v. State, 501 S.W.2d 124 (Tex. Crim. App. 1973) (pleading and proof rules)
  • Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for sufficiency of the evidence)
  • Mason v. State, 905 S.W.2d 570 (Tex. Crim. App. 1995) (applying Jackson standard)
  • Johnson v. State, 43 S.W.3d 1 (Tex. Crim. App. 2001) (insufficient evidence undermines confidence in verdict)
  • Dorsey v. State, 55 S.W.3d 227 (Tex. App. 2001) (plea offer bindingness discussion)
  • State v. Moore, 240 S.W.3d 248 (Tex. Crim. App. 2007) (plea offers and court approval)
  • Ex parte Williams, 637 S.W.2d 943 (Tex. Crim. App. 1982) (plea negotiation principles)
  • Mabry v. Johnson, 467 U.S. 504 (U.S. 1984) (due process concerns in plea bargaining and vindictiveness)
Read the full case

Case Details

Case Name: Wingfield, Anthony Bernard
Court Name: Court of Appeals of Texas
Date Published: Dec 15, 2015
Docket Number: PD-1618-15
Court Abbreviation: Tex. App.