Noel Ronaldo Villarreal, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that the evidence was legally sufficient to support Villarreal's conviction for violating a protective order even though the order's page-two definition of 'family violence' omitted dating violence: a rational jury, reading the order as a whole in the context of all the evidence and the jury instructions, could find beyond a reasonable doubt that his assault on Shannon Love violated the order. The Court dismissed the factual-sufficiency ground for review as improvidently granted because deciding it would require an impermissible de novo review of the court of appeals' determination, and it held there was no jury-charge error because the trial court was statutorily obligated to define the Family Code terms affecting the 'family violence' element. The judgment of the court of appeals was affirmed. Judge Hervey, joined by Judge Keasler, concurred with reservations, disagreeing with the majority's 'any reasonable person' framing and with any suggestion that actual knowledge of the order's contents is required for liability.