Court of Criminal Appeals of Texas, 1997

The Court held that the court of appeals applied factual-sufficiency review incorrectly because it failed to defer to the jury’s credibility determinations and did not consider all the evidence impartially.

The court reversed the court of appeals and affirmed the trial court’s denial of suppression, holding that the officers had probable cause to arrest Guzman under the totality of the circumstances.

The court held that evidentiary sufficiency is measured by the elements of the offense under a hypothetically correct jury charge, not by the jury charge actually given. It overruled the doctrine that made an unobjected-to charge error increase the State’s burden for sufficiency review, and held that the legality of…