Villarreal v. Texas (original by judge alcala)
Annotate this CaseIn September 2010, appellant Rene Villarreal was arrested and charged with the murder of Christopher Martinez. The issue presented for the Court of Criminal Appeals' review centered on whether a defendant has suffered egregious harm from the erroneous omission of a jury instruction that would have required the jury to apply a presumption of reasonableness as to his belief that the use of deadly force was immediately necessary to protect himself. The State raised this question in its petition for discretionary review, in which it challenged the court of appeals’s reversal of appellant's murder conviction based on the conclusion that he was egregiously harmed by the trial court’s omission of such an instruction. The Court of Criminal Appeals agreed with the State’s contention that the court of appeals erred by concluding that appellant was egregiously harmed based on the existence of theoretical harm and based on an incomplete review of the record and the arguments of counsel. The judgment of the court of appeals was reversed and the matter remanded for further proceedings.
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