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defendantappealtrialsustainedappellantgrand jury

appealtrialappellant

Related Cases

Shaw v. State, 243 S.W.3d 647

Facts

In February 2002, a grand jury indicted Rebecca Shaw for injury to a child after her ten-week-old grandson, Schuyler, sustained severe brain injuries that led to his death. The State presented evidence that Shaw had shaken Schuyler out of frustration when he would not stop crying. During the trial, Shaw claimed she attempted to perform CPR on Schuyler when she found him unresponsive, but the jury convicted her of recklessly causing serious bodily injury.

The jury subsequently found the appellant not guilty of intentionally or knowingly causing serious bodily injury to Schuyler Shaw but found her guilty of recklessly causing serious bodily injury to him.

Issue

Did the trial court err in denying the appellant's request for a jury instruction on the Good Samaritan defense?

The appellant asked the trial court to instruct the jury on the Good Samaritan defense provided by Texas Penal Code § 22.04(k)(1)(B) (later recodified, with its text unchanged, as Texas Penal Code § 22.04(k)(2)).

Rule

A defendant is entitled to a jury instruction on a defense if there is evidence in the record that supports a rational inference that the defense is applicable.

In Texas Penal Code § 2.03(c), the Legislature mandated that '[t]he issue of the existence of a defense is not submitted to the jury unless evidence is admitted supporting the defense.'

Analysis

The court determined that the evidence presented did not support the Good Samaritan defense because it did not show that Shaw's actions were reasonable emergency medical care. The court emphasized that the evidence must support a rational finding that the defendant's conduct was justified under the circumstances, which was not the case here.

The court of appeals explained that, '[b]ecause a rational juror could not have found that Shaw's conduct in shaking the baby and hitting its head against an object was reasonable emergency medical care or that Shaw was not licensed in the healing arts, the defense in question was not raised.'

Conclusion

The Court of Criminal Appeals affirmed the judgment of the court of appeals, concluding that the trial court did not err in denying the requested jury instruction on the Good Samaritan defense.

We hold that the court of appeals applied the correct legal standard in determining whether the evidence 'raised' the 'Good Samaritan' defense in this case.

Who won?

The State prevailed in the case because the court found that the evidence did not support the Good Samaritan defense, affirming the conviction.

The State argued first that 'the trial court did not err in denying [the requested] jury instruction because there was no evidence in the record to raise same.'

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