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Guyger v. Texas
Texas Court of Appeals
2021 WL 3438073 (2021)
Facts
One night, Amber Guyger (defendant), a police officer, arrived at her apartment complex and parked in the garage. Guyger mistakenly parked on the garage’s fourth floor and entered a hallway on the fourth floor of the complex. Guyger’s apartment was on the third floor. Guyger mistook Botham Jean’s apartment on the fourth floor for her own. It was not uncommon for the complex’s residents to end up on the wrong floor or at the wrong apartment door because the apartment complex is not well marked. When she approached the door to the apartment, Guyger heard noise inside. Guyger stated that she believed there was a threat inside her apartment before she opened the door. Instead of taking a position of cover and concealment or calling for backup, Guyger entered the apartment. Guyger encountered Jean who exclaimed, “Hey, hey, hey,” as Guyger entered. The evidence is unclear as to exactly what happened next, but Jean was unarmed. Guyger shot twice, hitting Jean once. Guyger quickly realized her mistake and called 911. Jean died from the gunshot wound. A jury convicted Guyger of murder. Guyger appealed, arguing that the evidence was not legally sufficient and that the trial court erred in failing to give a jury instruction on mistake of fact because Guyger’s mistake of fact negated the requisite intent to kill.
Rule of Law
Issue
Holding and Reasoning (Burns, C.J.)
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