Devan Curtis Meeks v. State

Citation: Not availableDocket: 01-10-00905-CR

Court: Court of Appeals of Texas; October 6, 2011; Texas; State Appellate Court

Original Court Document: View Document

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On October 6, 2011, the Court of Appeals for the First District of Texas affirmed the conviction of Devan Curtis Meeks for murder, with a sentence of sixty years’ confinement. Meeks contested the sufficiency of the evidence supporting his conviction. The case background reveals that in the summer of 2008, nineteen-year-old Meeks was dating sixteen-year-old Melina Perry, who had moved into the home of David Davis, a close family friend. Davis, concerned about their relationship and Perry's well-being, eventually evicted Meeks due to his refusal to find work and threats he had made against Davis.

Four days after Perry wrote a letter expressing violent thoughts about Davis, Meeks attacked him but stopped when Perry left the scene. Following this, Meeks and Perry fled to Meeks's grandfather's house, where Meeks stole a truck with the intention of escaping. They returned to Davis's house early the next morning, where Perry informed Meeks that it was time to kill Davis. When Davis confronted them with a hedge clipper, a physical altercation ensued, during which Perry stabbed Davis multiple times in the back and ultimately cut his throat, leading to Davis’s death. Meeks initially claimed he knocked Davis out but later recanted, stating his actions were limited to pushing Davis backward. Perry's violent actions included stabbing Davis in the heart and striking him with a hedge clipper.

Meeks gathered various weapons, including a hedge clipper and knives, which he wrapped in a shirt and placed in his truck alongside Perry's clothing. He also stole a dresser drawer from Davis's home that contained marijuana. Perry ignited gasoline around the house using Meeks's lighter and left the gas canister in the truck. After the incident, Meeks disposed of the weapons and shirt in the woods while fleeing to his father’s house in Oklahoma. Both Meeks and Perry were apprehended by the police shortly after their arrival. Upon arrest, Meeks urged Perry not to speak and denied involvement in stabbing Davis, claiming he did not plan to kill him and resisted Perry's intentions. Evidence found by the police included blood on the truck's steering wheel, driver’s seat, and the gas canister, as well as a pocket knife on Davis’s porch, which Meeks claimed to have lost prior to the incident. Forensic testimony indicated Davis died from a stab wound to the chest, with additional non-lethal wounds and severe burns on his body.

In the legal context, the standard for reviewing legal and factual sufficiency challenges requires that a conviction be supported by evidence that, when viewed favorably to the verdict, allows a rational factfinder to find the essential elements of the crime beyond a reasonable doubt. Murder can be charged if a person intentionally or knowingly causes death or intends to cause serious bodily injury through dangerous actions. Under the law of parties, a defendant can be found guilty if they promoted or assisted in the commission of the offense. Events surrounding the crime may be considered for assessing criminal responsibility.

The trial court provided instructions to the jury regarding two theories of murder concerning Meeks: as a primary actor and as a party to the offense. The analysis focused on the sufficiency of evidence to support Meeks’s conviction as a party to the offense, as established by the precedent that a guilty verdict can be upheld based on any one theory if sufficient evidence exists (Guevara v. State). Meeks argued that the evidence was insufficient because he did not intend to assist Perry in Davis’s murder. However, the court found otherwise, noting that Meeks's involvement before, during, and after the crime demonstrated intent. Specific actions included Meeks threatening Davis, physically attacking him, and participating in the assault alongside Perry, who ultimately delivered the fatal stab. The jury was presumed to have resolved conflicting evidence in favor of the verdict.

Following the murder, Meeks’s actions—gathering weapons, assisting in packing Perry’s belongings, stealing from Davis, and fleeing to Oklahoma—were viewed as circumstantial evidence of guilt. The court affirmed that under the law of parties, it is not necessary for a defendant to inflict the fatal injury to be convicted of murder, thus reinforcing the sufficiency of the evidence against Meeks. Ultimately, the court concluded that a rational jury could find Meeks guilty beyond a reasonable doubt, affirming the trial court's judgment.