Can non-verbal confirmation be used as evidence in court?

Mangawe v. The State of Texas

COA02 — February 5, 2026

Bengamiah Mangawe appealed a conviction for continuous sexual abuse, arguing that vague testimony regarding dates (like 'November-ish') failed to meet the 30-day statutory duration requirement. The Fort Worth Court of Appeals analyzed the evidence under a deferential standard, noting that a detective's testimony about Mangawe’s non-verbal 'nod' or confirmation of the timeline during an interview was substantive evidence. The court held that the jury is the sole arbiter of credibility and can resolve chronological conflicts in favor of the verdict, even when dates are approximate or admissions are not captured on audio.