## Facts

- Calvin Haley, Jr. was convicted of murdering his girlfriend, Andrea White.
- White was shot in the head one night while Haley and White were alone in their bedroom.
- Haley claimed the shooting was accidental and occurred while he was cleaning his gun while standing next to White.
- Haley testified that, as he attempted to unload the gun, his finger hit the trigger and the gun fired.
- Haley waited about 40 minutes after the shooting before calling for help.
- At trial, Haley testified that he knew there was a bullet in the chamber while he was holding the gun.
- Haley also testified that he did not normally clean the gun in the same manner he did on the night White was shot.
- Evidence showed it took a substantial amount of force to pull the gun’s trigger.
- Evidence also showed the gun had not misfired in the past.
- At the time of White’s death, the relationship had become turbulent, and White had been trying to end it.
- On appeal, Haley argued the evidence was insufficient because it did not show he intended to kill White.

## Issues

1. Whether the evidence was legally sufficient to support the murder conviction by permitting a rational jury to find beyond a reasonable doubt that Haley intentionally or knowingly caused White’s death, rather than accidentally discharging the gun while cleaning it.

## Decision

- The First Court of Appeals (Houston) affirmed Haley’s murder conviction.
- The court held the evidence was sufficient to support the jury’s finding that Haley acted intentionally or knowingly in causing White’s death.

## Legal Principles

- In a legal-sufficiency review, an appellate court asks whether, viewing the evidence in the light most favorable to the verdict, any rational factfinder could have found the offense’s elements beyond a reasonable doubt.
- A defendant’s intent is commonly proved through circumstantial evidence and reasonable inferences drawn from the defendant’s conduct and the surrounding circumstances.
- The jury may accept or reject all or part of a witness’s testimony, including a defendant’s claim of accident, and appellate courts generally defer to the jury’s credibility choices and conflict resolution.
- Evidence such as handling a loaded firearm, the mechanics of the weapon (including trigger force and history of reliability), relationship conflict, and delay in seeking help can support an inference of an intentional or knowing killing.

## Conclusion

The court affirmed Haley’s conviction because the jury was entitled to reject Haley’s accidental-shooting account and infer an intentional or knowing killing from the circumstances, including Haley’s admitted awareness of a chambered round while handling the gun next to White, evidence that the trigger required substantial force and the gun had not misfired previously, testimony about relationship turmoil and White’s efforts to end the relationship, and Haley’s delay in calling for help.


Haley v. State, 2004 WL 2415122 (2004)