McClure v. State
575 S.W.2d 564 (1979)
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Rule of Law:
In a prosecution for murder or voluntary manslaughter, evidence of the deceased's infidelity and expert psychiatric testimony are relevant and admissible to show the accused's state of mind at the time of the offense, provided the accused had knowledge of the infidelity.
Facts:
- McClure was married to the deceased.
- During their marriage, the deceased engaged in sexual relations with at least three other men: Keith Crowder, Harvey Gordon, and Ronnie Davis.
- A third party, Cindy Haynes, informed McClure that his wife had been having sexual relations with Crowder and Davis.
- McClure personally witnessed his wife leave for a 'date' with Gordon and not return until 10 a.m. the next day.
- McClure also saw his wife having breakfast with Crowder, at which time McClure appeared 'real nervous, shaky, upset.'
- A court-appointed psychiatrist, Dr. James Huddleston, examined McClure after the offense and concluded he suffered from chronic depression and a strong feeling of rejection from his marital difficulties.
- Immediately before McClure shot his wife, she said goodbye to him and turned to leave, an action the psychiatrist characterized as a 'culmination of the rejection appellant had been experiencing.'
Procedural Posture:
- McClure was prosecuted for the murder of his wife in a Texas trial court.
- At trial, McClure sought to introduce testimony from three men regarding their sexual relations with his wife, his own testimony about being told of the infidelity, and testimony from a psychiatrist about his mental state.
- The trial court excluded this evidence from being presented to the jury.
- The jury convicted McClure of murder and sentenced him to 99 years in prison.
- McClure (appellant) appealed the conviction to the Texas Court of Criminal Appeals, arguing the trial court erred by excluding the evidence.
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Issue:
Does a trial court err in a murder prosecution by excluding evidence of the deceased spouse's infidelity and related expert psychiatric testimony when that evidence is offered to show the defendant's state of mind and support a claim of voluntary manslaughter?
Opinions:
Majority - Presiding Judge Onion
Yes. A trial court errs by excluding such evidence. Under Texas Penal Code § 19.06, a defendant in a murder or voluntary manslaughter case must be permitted to offer all relevant facts and circumstances that show their state of mind at the time of the offense. Long-standing precedent establishes that evidence of a spouse's infidelity is admissible for this purpose, as it can show the defendant acted under a state of passion that could reduce murder to voluntary manslaughter. For the evidence to be admissible, the defendant must have had knowledge of the infidelity. McClure's testimony about what Cindy Haynes told him was not inadmissible hearsay because it was offered to prove its effect on his state of mind (his knowledge), not to prove the truth of the statement itself. Because McClure could establish knowledge, the testimony of the men involved in the infidelity and the expert psychiatric testimony explaining the psychological impact of these events were both relevant and should have been admitted.
Analysis:
This case reinforces the broad scope of Texas Penal Code § 19.06, emphasizing that any evidence relevant to the defendant's state of mind is critical in a homicide trial. The decision clarifies a key exception to the hearsay rule, affirming that an out-of-court statement is admissible if offered not for its truth, but to show the statement's effect on the listener's mental state. This precedent is crucial for defendants seeking to mitigate a murder charge to voluntary manslaughter, as it ensures they can present a complete picture of the psychological pressures, such as knowledge of a spouse's infidelity, that may have led to the offense.
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