Amber Renee Guyger v. the State of Texas
Texas Court of Appeals, 5th District (Dallas) · 2021
Facts
Amber Renee Guyger, a Dallas police officer, lived in apartment 1378 at the Southside Flats Apartments. On September 6, 2018, after work, Guyger mistakenly parked on the fourth floor of her apartment complex, believing it was the third. She then walked to apartment 1478, believing it was her own apartment, 1378. The door to apartment 1478 was ajar, and Guyger used her key fob, which opened the door further. Inside, she saw a "silhouette figure," Botham Jean, the lawful resident of apartment 1478. Believing Jean was an intruder and a threat, Guyger pulled her weapon, yelled, "Let me see your hands," and fired two shots, intending to kill him. One shot struck Jean in the chest, causing his death. Guyger then realized her mistake, called 911, and attempted chest compressions on Jean, who later died.
Procedural history
Amber Renee Guyger was convicted of murdering Botham Jean and sentenced by a jury to ten years’ imprisonment by the 204th Judicial District Court in Dallas County, Texas. This appeal followed, bringing the case to the Court of Appeals, Fifth District of Texas at Dallas.
Issue
1. Is the evidence legally insufficient to support Guyger's murder conviction, specifically regarding her mistaken belief about entering her apartment and the right to act in deadly force in self-defense? 2. In the alternative, should the court acquit Guyger of murder, convict her of criminally negligent homicide, and remand for a new punishment hearing?
Holding
The court affirmed the trial court's judgment, finding the evidence legally sufficient to support the murder conviction. It overruled Guyger's arguments regarding insufficient evidence for murder and the alternative request for conviction of criminally negligent homicide.
Rule
Legal sufficiency of evidence requires that, viewing evidence in the light most favorable to the verdict, any rational trier of fact could have found essential elements of the crime beyond a reasonable doubt. Murder is committed if a person intentionally or knowingly causes the death of an individual. Mistake of fact is a defense if a mistaken belief negates the culpable mental state for the offense, but it applies only to elements requiring proof of a culpable mental state and does not negate intent to kill if the mistake relates to justification. Self-defense justifies force when an actor reasonably believes it is immediately necessary to protect against unlawful force, but the jury can reject this defense if the belief was not reasonable or if the actor had other safe options.
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