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Francisco Rodriguez Chacon v. State
Citation: Not availableDocket: 07-07-00029-CR
Court: Court of Appeals of Texas; February 13, 2008; Texas; State Appellate Court
Frank Chacon was convicted of murder and appealed the conviction on two grounds: the alleged improper reliance on accomplice witness testimony lacking corroboration and the claim that the evidence was legally and factually insufficient to support the verdict. The court affirmed the judgment, highlighting the involvement of Chacon in a drug operation led by Craig Kimberlin, which was threatened by rival drug dealer Dustin Pool. After Pool was lured to an apartment, he was brutally assaulted and ultimately died from blunt force trauma and/or asphyxiation. Chacon's argument regarding the necessity of corroboration for accomplice testimony was overruled. The court clarified that while a conviction cannot solely rely on accomplice testimony, the corroboration required need not directly link the defendant to the crime but should merely connect him to the offense in some way. Chacon’s own statement confirmed his presence at discussions about Pool and the potential hiring of someone to kill him, contributing to the evidence against him. Appellant traveled to the murder scene with Kimberlin, was informed about the handling of Pool's body post-murder, and participated in purchasing materials to conceal the body, which connects him to the crime, though it does not alone prove guilt. The court referred to precedent in Rule v. State, asserting that presence at the murder scene and involvement in body disposal can indicate complicity. Appellant contested the sufficiency of evidence for his conviction, but the court upheld the standards set in Jackson v. Virginia and Watson v. State. The medical examiner concluded Pool died from blunt force injuries and asphyxia. Evidence indicated that Pool suffered significant head trauma, including a skull fracture from multiple blows. Appellant claimed he was uninvolved in the initial kidnapping and not responsible for the fatal blow, arguing suffocation was the only means of murder attributed to him. However, it was established that Pool survived for some time after the initial injury, and witness Bledsoe testified that appellant struck Pool with pliers. This evidence allowed a rational jury to find him guilty beyond a reasonable doubt. Despite inconsistencies in witness statements, the jury was tasked with resolving these conflicts. Consequently, the court found the evidence sufficient to support the conviction and affirmed the trial court's judgment.