In re Commitment of Jeffery Lee Stoddard (Opinion)Annotate this Case
The Supreme Court reversed the judgment of the court of appeals reversing a jury's finding that Jeffery Lee Stoddard was a sexually violent predator (SVP) and civilly committing him under Tex. Health & Safety Code chapter 841, holding that the court of appeals applied an improper standard.
The court of appeals described the standard governing the factual sufficiency review in which the burden of proof was beyond a reasonable doubt the court of appeals described the standard as requiring the court to weigh the evidence in a neutral light to determined whether the jury's finding was factually insufficient or so against the great weight and preponderance as to be manifestly unjust, shock the conscience, or clearly demonstrate bias. The Supreme Court reversed, holding (1) the court of appeals applied an improper standard that allowed the court to substitute its own judgment for that of a reasonable fact-finder and incorporated a statutory element that chapter 841's text did not support; and (2) a properly conducted factual-sufficiency review in an SVP case requires the appellate court to determine whether, on the entire record, a reasonable factfinder could find beyond a reasonable doubt that the defendant is an SVP.