PD-1000-20 01/13/2021
1. “The Fourteen Court of Appeals misapplied Texas Rules of Evidence 401 and 402 by disregarding evidence connecting Appellant to Cassie’s murder and, thus, erroneously concluding that the extraneous-offense evidence of Cassie’s murder was irrelevant.”
2. “The Fourteenth Court of Appeals erred by failing to consider whether the extraneous-offense evidence of Cassie’s murder was admissible under Texas Rule of Evidence 404(b) for the non-character-conformity purposes of: demonstrating that Appellant restrained Cassie without her consent; showing Appellant’s intent to use deadly force against Cassie to prevent her liberation; and providing same-transaction contextual evidence.”
3. “The Fourteenth Court of Appeals failed to conduct a meaningful assessment of whether, per Texas Rule of Evidence 403, the probative value of the extraneous-offense evidence of Cassie’s murder was substantially outweighed by the danger of unfair prejudice.”
Inthalangsy was charged with the capital murder of Kris Maneerut in the course of kidnaping or attempting to kidnap Maneerut’s girlfriend, Sara Cassandra “Cassie” Nelson. Cassie had been involved with drug dealers who blamed her for a large deal that went bad. She had been kidnaped earlier in the week by a group including Inthalangsy but secured her release with the promise of a boat. When the title could not be located, the dealers decided to kidnap her again. The last time she was seen alive was by a witness who saw her escorted to a car from a house where, moments later, that witness found Maneerut dying from a gunshot wound to the face. Cassie’s body was found the next morning by the river. She was shot many times, including twice in the face. The trial court admitted the evidence of the extraneous murder. Inthalangsy was convicted.
The court of appeals reversed. Although it conceded that “it is easy to imagine a connection between [Inthalangsy]’s conduct and Cassie’s violent death,” it held that 1) Cassie’s murder was irrelevant because it was not proved beyond a reasonable doubt, 2) “[her] death had no logical tendency to make a fact of consequence concerning her kidnapping more or less probable than it would have been without her death,” 3) the evidence of her kidnaping was legally sufficient without it, 4) the facts of her murder were inherently prejudicial, 5) “[t]his prejudice was unfair and substantially outweighed the non-existent probative value of Cassie’s death,” and 6) Inthalangsy was harmed. The
dissent disagreed on all points. It would have held that the murder was relevant for multiple permissible purposes under TEX. R. EVID. 404(b), and the evidence—when viewed properly—supported Inthalangsy’s guilt of the extraneous offense. As a result, “a meaningful analysis under Rule 403” would have shown the trial court’s ruling was within the zone of reasonable disagreement.
The State’s argument on petition tracks the analysis of the dissent.
