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Morales v. State

557 S.W.3d 569 (Tex. Crim. App. 2018)

Good LawTexas Court of Criminal AppealsOctober 3, 2018Cited 189 times

Quick Take

Morales v. State is a significant case in Criminal Defense law, with 189 citations. It's regularly referenced in legal arguments and court opinions. Its citation status is "good law," meaning courts continue to follow and affirm this ruling — it remains authoritative.

How to Use This Case

When to cite:

This case has good-law status and is regularly cited in Criminal Defense arguments. It's appropriate to cite when you need authority on Self-defense instruction threshold or Low burden for defensive issues.

Key arguments it supports:

  • A defendant is entitled to a self-defense instruction if any evidence raises the issue, regardless of its strength or credibility
  • Evidence is viewed in the light most favorable to the defendant when determining entitlement to the instruction
  • The trial court may not weigh evidence or assess credibility in deciding whether to submit the instruction

Court level & jurisdiction:

As a Texas Court of Criminal Appeals decision, this ruling is binding within its circuit and persuasive in other jurisdictions. With 189 citations, courts clearly find it authoritative.

Summary

The Texas Court of Criminal Appeals addressed when a defendant is entitled to a jury instruction on self-defense and clarified the low threshold for raising the defense. The court held that a defendant is entitled to a self-defense instruction if there is some evidence, from any source, when viewed in the light most favorable to the defendant, that would support the defense — even if that evidence is weak, contradicted, or not credible.

The court emphasized that the trial court's role is not to weigh the evidence but merely to determine whether any evidence raises the issue.

Key Holdings

  • 1A defendant is entitled to a self-defense instruction if any evidence raises the issue, regardless of its strength or credibility
  • 2Evidence is viewed in the light most favorable to the defendant when determining entitlement to the instruction
  • 3The trial court may not weigh evidence or assess credibility in deciding whether to submit the instruction

Why This Case Matters

Reinforces the low threshold for self-defense jury instructions in Texas, providing defense attorneys strong authority to demand the instruction even with minimal supporting evidence.

Facts

Defendant was convicted of aggravated assault. At trial, defendant testified that the complainant attacked him first and he responded in self-defense. The trial court refused to submit a self-defense instruction, finding the defendant's testimony not credible.

Legal Principles

Self-defense instruction thresholdLow burden for defensive issuesTrial court gatekeeping limitations

Statutes Interpreted

  • Tex. Penal Code § 9.31
  • Tex. Penal Code § 9.32

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