Hart v. Texas (original by judge slaughter)
Annotate this CaseRonald Ray, the victim in this case, was engaged in a tumultuous, on-again-off-again relationship with Appellant Robert Hart’s adult daughter, Stephanie. According to Stephanie, the relationship was one filled with violent abuse. On September 22, 2016, shortly before 1 p.m., Ray showed up unannounced in the street outside the Hart family home. Inside the home at the time were Appellant, his wife Elizabeth, Stephanie, and his other daughter. The family’s home had a security camera with a viewing monitor inside. Ray parked his vehicle across the street, got out, removed his shirt, and began smoking a cigarette. Panicked, the girls told their father that Ray was outside. In video footage, Ray was seen standing next to the open driver-side door of his car in the street. Appellant walked towards Ray while holding a gun at his side. Appellant and Ray briefly yell at one another, but it was unknown what exactly was said. Within seconds, Appellant pointed the pistol at Ray, who put his hands up and shrugged his shoulders. Appellant then almost immediately began firing at Ray, who ran towards the back of his vehicle and around to the passenger side. After pacing for a few seconds, Ray collapsed near the back of his vehicle. Appellant was ultimately convicted of murder, and he appealed, arguing his trial counsel was ineffective for declining the trial court’s offer to include a sudden-passion jury instruction in the punishment-phase charge. The Texas Court of Criminal Appeals determined the existing direct-appeal record was inadequately developed. "Had the record contained a motion for new trial raising an ineffectiveness claim, counsel would have had an opportunity to explain why he declined the sudden-passion instruction. Such an explanation could have contained a plausible strategic reason for counsel’s decision." Therefore, based on the trial court record, the Court of Criminal Appeals could not hold that counsel’s decision to decline the sudden-passion instruction was so outrageous that no competent attorney would have engaged in it. The Court reversed the court of appeals’ judgment granting Appellant a new punishment trial, and the case was remanded to that court for further proceedings.
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