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654 S.W.2d 465

Wilson v. State

Court of Criminal Appeals of Texas

Decided March 23, 1983

Court of Criminal Appeals of Texas · decided 1983-03-23

Key passage — most relied on by later courts

“[Circumstantial evidence should not be tested by an ultimate “standard for review” different from direct evidence; the standard in both kinds of cases is whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt [Emphasis in the original].”

quoted by 10 later decisions, including Shipley v. State, Mattias v. State

“Logic dictates that if there is a “reasonable hypothesis” other than the guilt of the accused, then it cannot be said that the guilt has been shown “beyond a reasonable doubt.””

quoted by 2 later decisions, including Zimmerman v. State, Michalenko v. State

Relies on Hankins v. State

Good law ✅— No negative treatment on recordhow we know

Decided 1983-03-23

How this case has been cited

Cited by 282 later decisions — most recently September 2005 · most notably Geesa v. State (1991), Harris v. State (1989)

2 federal appellate · 280 state decisions

2320198319902000decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

McCORMICK, Judge,

¶1concurring.

¶2I agree that the standard for review in any case is whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. I write to emphasize that application of the “exclusion of outstanding reasonable hypotheses” analysis is, as stated by the majority, one criteria which may be applied in arriving at the answer to the ultimate result, but it should not be considered an element of that ultimate standard. And as the majority emphasizes, the method of analysis does not change this standard of review.

¶3Logic dictates that if there is a “reasonable hypotheses” other than the guilt of the accused, then it cannot be said that the guilt has been shown “beyond a reasonable doubt.” In Hankins v. State, 646 S.W.2d 191 (Tex.Cr.App.1983), we recognized that direct and circumstantial evidence were to be treated with equal dignity. Thus, any effort to weave into the standard of appellate review any exception or difference or special treatment for one type of evidence or the other will fail for lack of logic.

¶4Lastly, in applying this standard to the cases before us, the final outcome is the same. Therefore, I concur in the overruling of the States’ motions for rehearing in each case.

TOM G. DAVIS, W.C. DAVIS and TEAGUE, JJ., join in this concurrence.
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