Court of Criminal Appeals of Texas

Douglas Arthur McCuin, Appellant v. the State of Texas, Appellee

March 6, 19741974 Tex. Crim. App. LEXIS 1393

Summary

The Court held that the trial court erred by overruling the appellant’s objection to an abstract charge on the law of principals, because the evidence was insufficient to sustain a conviction without applying the principals doctrine. Accordingly, the murder conviction was reversed and the case remanded. The Court clarified the Durham and Oliver rules governing when a principals instruction is required. Justice Douglas, concurring, agreed with the result but cautioned against prescribing future charge guidelines.