Beunka Adams v. State

Citation: Not availableDocket: 12-03-00112-CR

Court: Court of Appeals of Texas; January 29, 2004; Texas; State Appellate Court

Original Court Document: View Document

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Beunka Adams appeals the trial court's denial of his application for a writ of habeas corpus seeking bail after being charged with capital murder. The trial court found sufficient evidence supporting the claim that Adams committed a capital offense, leading to the denial of bail. Adams had previously filed two applications for writs of habeas corpus, both of which were denied, prompting this appeal. 

During the hearing for the second application, evidence included testimonies from two surviving victims, a sheriff's deputy, and the fire chief, detailing the events of the crime. Adams and an accomplice, Richard Cobb, entered a convenience store with a shotgun to rob it. After taking money, they forced the store clerks and a customer into a vehicle, where Adams was recognized by one of the clerks. They drove to a remote location where Adams sexually assaulted one victim and subsequently shot both victims after binding their hands. Adams shot one victim in the face and physically assaulted the other before leaving the scene. One victim, who managed to seek help after the assailants left, provided police with details leading to the discovery of the injured and deceased victims. The court upheld the trial court's decision, affirming the denial of bail.

The trial court's denial of bail for the Appellant was based on the finding of "proof evident" of a capital offense, as outlined in Texas law. "Proof evident" is defined as clear and strong evidence, with the State carrying the burden to demonstrate this at the bail hearing, which requires a substantial showing of the accused's guilt, less than the standard of beyond a reasonable doubt. The court must conclude that (1) capital murder was committed, (2) the accused is guilty, and (3) there is a likelihood of conviction and imposition of the death penalty. Factors influencing the jury's decision regarding the death penalty include the accused's potential future dangerousness and mitigating circumstances.

The State's evidence indicated that the Appellant was involved in the events leading to Vandever's death via a gunshot during a kidnapping, robbery, and aggravated sexual assault, establishing that capital murder occurred. Additionally, the evidence suggested the Appellant played an active role in the robbery and kidnapping, and was the sole actor in the aggravated sexual assault, further supporting the trial court's conclusion of evident proof justifying the denial of bail. The appellate court must evaluate the sufficiency of this evidence to uphold the trial court's decision.

Cobb and Appellant kidnapped Dement, Driver, and Vandever after robbing a store. At a remote location, Appellant threatened the victims with a gun and was present when all three were shot. Evidence indicates that the murders were anticipated outcomes of their conspiracy. Although neither Dement nor Driver could identify who shot Vandever, the Appellant exhibited no change in behavior after the shooting, instead checking on the victims' status, threatening them, shooting Driver, and kicking Dement. This behavior suggests that Appellant either shot Vandever or participated in the crime. The court found substantial evidence supporting a conviction for capital murder. The discussion also considered the likelihood of the jury imposing the death penalty, highlighting that Appellant's involvement in aggravated robbery, kidnapping, and sexual assault indicated future violent tendencies. The use of a deadly weapon allowed for an inference of intent to kill. No mitigating circumstances were presented, reinforcing the expectation of a capital murder conviction and potential death sentence for Appellant. The trial court's denial of bail was deemed appropriate, leading to the affirmation of its judgment.