Mendez v. Texas (original by judge keasler)Annotate this Case
On August 5, 2011, some time after 2 A.M., Adrian Mendez and several friends arrived at Big Man Diesel Repair. The group had spent the evening socializing and consuming a variety of drugs. They were later joined by Roger Guzman and Jacob Castillo, who had also been smoking marijuana and drinking alcohol. Soon thereafter, Mendez and Castillo got into a fight. The men exchanged blows until Mendez drew a knife and stabbed Castillo several times. Castillo was hospitalized and, although his initial prognosis was good, he died two months later due to complications from his stab wounds. The State charged Mendez with murder. The jury acquitted Mendez of murder, but convicted him of the lesser-included offense of aggravated assault. Mendez was sentenced to seven years’ imprisonment and assessed a $10,000 fine. The Texas Court of Criminal Appeals sought to resolve a conflict among the lower courts, with some holding that, when a trial court sua sponte issues a defensive jury instruction but fails to apply it to a lesser-included offense, the court commits no error unless the defendant objects. Other courts have held that is error, even if the defendant doesn't object. The Court of Appeals determined the trial court in this case erred in sua sponte charging the jury on the issue of self-defense, and the Court of Criminal Appeals agreed: "[w]hen the trial court charged the jury on the issue of self-defense in the abstract, it thereby declared that issue to be law applicable to the case. The jury was informed under what circumstances it should convict Mendez of aggravated assault. Self-defense being law applicable to the case meant that the trial court should also have informed the jury under what circumstances it should acquit him of that offense."