Court of Criminal Appeals of Texas
Luis Alberto Plata, Appellant v. the State of Texas, Appellee
June 26, 19961996 Tex. Crim. App. LEXIS 86
Summary
The Court of Criminal Appeals affirmed the lower appellate court's decision that the trial court's jury charge did not authorize a conviction for vicarious criminal liability because the application paragraph lacked the necessary elements, and therefore the conviction was void. The majority held that abstract instructions alone cannot support a guilty verdict, while a dissent argued that the abstract definition sufficed and that the evidence supported a principal conviction.