Morales v. State
557 S.W.3d 569 (Tex. Crim. App. 2018)
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
Statutes Interpreted
- Tex. Penal Code § 9.31
- Tex. Penal Code § 9.32
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