Ex parte Christopher Rion (original by judge walker)
Annotate this CaseAppellant Christopher Rion crashed his vehicle into another vehicle, leading to injuries to the other vehicle’s driver and the eventual death of its passenger. For that death, Appellant was charged with manslaughter, but the jury found him “not guilty” of that offense and of the lesser included offense of criminally negligent homicide. The State proceeded to prosecute Appellant for the injuries to the driver on a charge of aggravated assault for intentionally, knowingly, or recklessly causing bodily injury with a deadly weapon. Appellant challenged the second prosecution as barred by collateral estoppel. The court of appeals held that collateral estoppel applied and barred the subsequent prosecution for reckless aggravated assault because the jury in the manslaughter trial decided that Appellant was not reckless in causing the collision, which would be an essential element in the aggravated assault trial. The Texas Court of Criminal Appeals reversed: although both trials involved the issue of whether Appellant was reckless, manslaughter and aggravated assault causing bodily injury were “result of conduct” offenses. The results, death and bodily injury, were different, and the culpable mental state of recklessness attached to those results. "By its verdict of 'not guilty' in the first trial, the jury necessarily determined that Appellant was not reckless and therefore necessarily determined that Appellant was not aware of a risk of death as a result of his conduct. But the jury did not necessarily determine that Appellant lacked awareness of a risk of bodily injury as a result of his conduct. Collateral estoppel does not prohibit the subsequent prosecution for reckless aggravated assault causing bodily injury."
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