Michael Anthony Fuller, Appellant v. the State of Texas

Summary

The Court held that the victim's name is not a substantive element of the offense of injury to an elderly individual, so the evidence was sufficient under Jackson v. Virginia. It also found the variance between the indictment's naming of "Olen M. Fuller" and the trial's reference to "Mr. Fuller" or "Buddy" to be immaterial under Gollihar, reversing the Court of Appeals and remanding for further proceedings. A dissent urged remand to reconsider the variance under Gollihar, while two concurrences affirmed the majority's result but expressed differing views on the historical treatment of Malik and Jackson.