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Crayton v. State - No. 03-14-00570-CR, 2016 Tex. App. LEXIS 11183 (Tex. App. Oct. 14, 2016)


When reviewing the sufficiency of the evidence to support a conviction, the court considers all the evidence in the light most favorable to the verdict to determine whether, based on that evidence and the reasonable inferences that can be drawn from it, any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt. In its analysis, the court assumes that the trier of fact resolved conflicts in the testimony, weighed the evidence, and drew reasonable inferences in a manner that supports the verdict. The court considers only whether the jury reached a rational decision. The court's role on appeal is restricted to guarding against the rare occurrence when a factfinder does not act rationally. 


Defendant Eric Byron Crayton was involved in an altercation with a man named Thomas Kitto that resulted in Kitto's death. Crayton was charged by indictment with murder and tampering with physical evidence. At trial in Texas state court, he filed a motion to suppress a recorded statement he had provided to police; the motion was denied. Nonetheless, a jury acquitted him of murder and convicted him of tampering with physical evidence. Crayton pleaded "true" to enhancement paragraphs alleging two prior felony convictions, and the jury assessed punishment at 35 years' imprisonment. Crayton appealed, challenging the trial court's denial of his motion to suppress and the sufficiency of the evidence to support his conviction for tampering with physical evidence. 


Was Crayton's conviction proper?




The state appellate court affirmed the conviction and the denial of Crayton's motion to suppress. The court explained that his recorded statements complied with Tex. Code Crim. Proc. Ann. art. 38.22, even though the warnings were contained only within a prior recording and not within the recording at issue, because the second interview was essentially a continuation of the first. The evidence also established that a detective read Crayton his Miranda rights twice and Crayton indicated that he understood; that only 55 minutes passed; that Crayton stayed in the same interview room the entire time; and that the first detective stayed during the second detective's interrogation. On the charge of tampering with physical evidence, the court held that the evidence was sufficient that Crayton knew that an offense had been committed when he disposed of a knife; the jury's decision to acquit him of murder based on self-defense did not mean that the murder did not occur.

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