Arthur Lee Williams, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals affirmed Arthur Lee Williams’ conviction for tampering with physical evidence, holding that a rational jury could find he knowingly destroyed a crack pipe while a weapons investigation was in progress and intended to impair its evidentiary value. The Court rejected the Pannell requirement that the defendant be aware the item is evidence in the specific investigation, interpreting the statute’s knowledge element broadly under its plain meaning. It also interpreted “destroy” by its ordinary meaning as rendering the item useless, satisfying the destruction element. Justice WOMACK filed a concurring opinion agreeing with the majority but noting that destruction may also be considered an alteration.