What evidence is needed to prove intoxication manslaughter vs murder in Texas?
This question has been addressed in 2 Texas court opinions:
Stanley Lewis II v. The State of Texas
COA14 — January 29, 2026
Stanley Lewis II appealed his intoxication manslaughter conviction, arguing that the victim's extreme intoxication (.233 BAC) and potential presence in the lane of traffic—rather than his own impairment—were the true causes of the fatal accident. The Fourteenth Court of Appeals analyzed the causation requirements under the Texas Penal Code, determining that Lewis’s failure to maintain a single lane, his increased speed, and his failure to brake established a sufficient "but-for" causal link to the death. The court affirmed the conviction, holding that a defendant's criminal liability is not negated by the victim’s concurrent negligence or intoxication when the defendant’s own impaired actions led to the fatal maneuver.
Litigation Takeaway
“In custody disputes involving substance abuse, a parent cannot escape a finding of endangerment by simply pointing to the other parent's "unclean hands" or concurrent intoxication. This case demonstrates that if a parent’s impairment leads to a dangerous maneuver or failure to avoid an accident, the other party's conduct is legally irrelevant to the determination of fault and safety risk.”
Woods v. State
COA05 — February 20, 2026
In Woods v. State, the Dallas Court of Appeals affirmed a murder conviction, focusing on how a defendant's actions after a crime can prove their intent. After killing a woman with a box cutter, Andre Woods sanitized the scene with bleach, moved the body, and fled from police. Woods argued on appeal that he should have received jury instructions for lesser offenses like manslaughter, claiming he "lost control." The court disagreed, holding that his deliberate efforts to conceal evidence and his own testimony regarding the attack established an intentional mental state. The court also ruled that graphic autopsy photographs were admissible because they were essential to explaining the medical examiner’s findings.
Litigation Takeaway
“Actions speak louder than words—especially actions taken after an incident. Evidence of "consciousness of guilt," such as cleaning a scene, deleting digital evidence, or fleeing, can be used to legally establish that an act of violence was intentional rather than accidental. In family law, this "bleach analogy" is a powerful tool to secure protective orders or a disproportionate share of property by negating claims that an injury was merely a reckless accident.”