Court of Criminal Appeals of Texas

Jaime Villa, Appellant v. the State of Texas

March 22, 20172017 Tex. Crim. App. LEXIS 288

Summary

The Court of Criminal Appeals held that the evidence was legally sufficient to support Villa's conviction for engaging in organized criminal activity as a member of the Barrio Azteca street gang. Viewed in the light most favorable to the verdict, the complainant's testimony that 'other gang members' — at least six — came toward him and that he then named six individuals including Villa permitted a rational jury to infer that Villa was a gang member, and that testimony alone sustained the conviction regardless of the expert-testimony and gang-rule issues the court of appeals had relied on. The Court reversed the court of appeals' insufficiency ruling and affirmed the trial court's judgment. No separate writings were filed.