Beltran v. State
PD-1076-14
Case Summary Written by Jonae Chavez, Staff Member.
JUDGE RICHARDSON delivered the opinion of a unanimous court.
On the night of the murder of Sheldon McKnight, Ramos, Beltran, and McKnight had been getting high and drinking Jack Daniels throughout the night. At some point in the evening, the three men went to McKnight’s apartment and continued to consume more drugs. Later, McKnight came downstairs and sat on the couch next to Beltran, “stroked his face and told Beltran he was a ‘pretty little thing.’” After resuming snorting heroin, Ramos and Beltran went upstairs because McKnight told them he was expecting company. Ramos later went back downstairs, leaving Beltran upstairs on the bed where he laid down and passed out with all of his clothes on.
Beltran testified that he was awakened by McKnight behind him and was now naked from the waist down, and McKnight was licking his anus. Beltran said that he panicked and tried to move, but McKnight jumped on top of him. At this point, Beltran was screaming in panic, not knowing what was going on. McKnight had Beltran’s face down into the pillow trying to shut him up when all of a sudden Ramos was in the room and hit McKnight with something. Ramos attempted to pull Beltran from under McKnight when McKnight grabbed Ramos. Then, Beltran grabbed McKnight from behind and told Ramos to get some help.
Ramos started stabbing McKnight who was “kicking” and “reacting crazy.” Beltran held McKnight tightly while Ramos continued to stab him to “protect” Ramos and himself from McKnight’s reactions. After realizing McKnight was dead, Beltran, who was totally naked and covered in blood, just started to cry. Beltran testified to being totally shocked, freaking out, and extremely scared. The two men left McKnight’s apartment in McKnight’s car. Beltran denied that he intended to rob and kill McKnight, denied that he intended to help Ramos kill McKnight, and denied killing or stabbing McKnight.
Beltran was charged with capital murder. The jury was given a self-defense charge, but rejected the self-defense charge. Beltran requested an instruction on sudden passion but the trial court denied the instruction. The jury came back with a punishment of seventy years imprisonment—with the instruction of sudden passion; the punishment would have been capped at twenty years.
Issue: Did the trial court err in denying Beltran’s request for an instruction on sudden passion?
First, the court analyzed whether Beltran was a criminally responsible party to the offense. “If the offense is committed by his own conduct, by the conduct of another for which he is criminally responsible, or by both,” then he is criminally responsible. The jury had to decide whether Beltran was guilty of causing the death of McKnight, either as acting as a party with Ramos who did the stabbing, or as the one who did the stabbing. Clearly, Beltran acted as a party with the primary actor who did the actual stabbing. Next, the court was faced with a unique question: whether Beltran’s conduct—acting as a party to the offense—was under the influence of sudden passion, or if Ramos’s conduct—the one who did the actual stabbing—was under the influence of sudden passion. Ultimately, the court found that “where the defendant is convicted as a party to the offence, the conduct of the primary actor is not relevant to whether the defendant acted deliberately.”
Sudden passion is a mitigating factor that determines the appropriate punishment of the defendant. Therefore, it was Beltran’s conduct by which “he act[ed] with intent to promote or assist the commission of the offense, and by which he encourage[d], aid[ed], or attempt[ed] to aid the other person to commit the offense that [wa]s determinative of whether he [was] entitled to a sudden passion instruction.” The Court of Appeals held that Beltran’s testimony showed that he was consciously aware of the danger McKnight posed and acted with thought, not in an excited or agitated state. However, courts must look for “some” evidence that a defendant acted with sudden passion—if there is at least some evidence, he is entitled to the instruction.
The Court of Criminal Appeals held that Beltran’s testimony raised some evidence of sudden passion. First, Beltran reacted under the immediate influence of terror, anger, rage, or resentment. Second, Beltran’s sudden passion was prompted by provocation by McKnight, and that provocation could commonly produce this sort of passion in a person of ordinary temper. Third, Beltran committed the murder, as a party, before a cool reflection. Fourth, there was a causal connection between Beltran’s passion, McKnight’s provocation, and the homicide.
The Court of Criminal Appeals held that the lower courts erred in denying Beltran’s request for a sudden passion instruction. There was evidence that Beltran acted under the immediate influence of terror. Although this evidence might have been weak, it was still enough to infer that Beltran acted under the immediate influence of terror.
The case was remanded for a harm analysis in accordance with Almanza v. State.