Unreported / Non-Citable
Background
On June 23, 2021, a fight broke out in the parking lot of Hurricane Harbor, an Arlington, Texas water park, as a group of patrons was leaving at closing time. Cameron Lavon Stephens, an affiliate of the Youngins In Charge (YIC) gang, confronted members of a rival group affiliated with the 2200 gang. After being knocked to the ground and beaten, Stephens retrieved a handgun from his car and fired multiple shots toward the group. Sixteen-year-old D.T., who witnesses said had not been involved in the fight, was struck in the back and died from a single gunshot wound.
The State charged Stephens with murder under two theories: intentionally or knowingly causing D.T.’s death, and intentionally committing an act clearly dangerous to human life with intent to cause serious bodily injury. Stephens pleaded not guilty, claiming self-defense and defense of his brother K.V. He testified that he fired over — not into — the group and did not aim at anyone. After about ninety minutes of deliberation, the jury convicted him and assessed a forty-year sentence. Stephens appealed, raising a single issue: that the evidence was legally insufficient to support the verdict and that the trial court erred in denying his motion for directed verdict.
Key evidence against Stephens included eyewitness Francisco Robles, who identified Stephens as the sole person he saw with a gun and said Stephens fired five to ten shots. Stephens’s brother K.V. and father Marcus had each made prior statements — later partially recanted — in which Stephens admitted he thought he had shot someone and had told his father he shot and killed a person at the water park. After the shooting, Stephens fled the scene and disposed of his firearm.
The Court’s Holding
The Second Court of Appeals, in a memorandum opinion by Justice Kerr joined by Chief Justice Sudderth and Justice Birdwell, affirmed the conviction. Applying the Jackson v. Virginia standard, the court held that the evidence, viewed in the light most favorable to the verdict, was legally sufficient for a rational jury to find beyond a reasonable doubt that Stephens intentionally or knowingly caused D.T.’s death, or that he intentionally committed an act clearly dangerous to human life with intent to cause serious bodily injury — whether D.T. was an unintended target or a bystander to whom Stephens’s intent transferred under Texas Penal Code § 6.04(b).
The court rejected Stephens’s argument that the absence of ballistics or trajectory evidence left the jury unable to infer intent beyond recklessness. It held that the jury could properly infer Stephens’s intent to kill from his use of a deadly weapon and his awareness that firing a gun in a crowded area at a busy water park on a summer evening was reasonably certain to result in death. The court also held that the jury, as the exclusive judge of witness credibility, was entitled to credit the eyewitness identification and the prior admissions to Stephens’s brother and father over the trial testimony attempting to walk those statements back.
On the self-defense and defense-of-others theories, the court found the evidence likewise sufficient for the jury to have found against Stephens on those defensive issues beyond a reasonable doubt. It noted that Stephens’s flight from the scene and disposal of his gun constituted circumstantial evidence of guilt that corroborated the incriminating statements, and that the jury could reasonably have concluded the force used was not legally justified under the circumstances.
Key Takeaways
- Firing into or toward a crowd in a populated area can support an inference of knowing murder even without ballistics or trajectory evidence — awareness that the conduct was “reasonably certain to cause death” suffices under Texas Penal Code § 6.03(b).
- Under Texas’s transferred-intent statute (§ 6.04(b)), a defendant who fires at a gang rival can be held criminally responsible for killing an uninvolved bystander struck by the same shot.
- Post-shooting flight and destruction of the weapon are circumstances of guilt that, combined with extrajudicial admissions, can corroborate a murder conviction even where witnesses recant or qualify their prior statements at trial.
- A self-defense claim requires the defendant to admit the otherwise unlawful conduct; once raised, the State need only prove its case beyond a reasonable doubt — it need not introduce affirmative evidence disproving the defense.
Why It Matters
This decision reinforces that Texas courts will uphold murder convictions in crowd-shooting scenarios based on circumstantial proof of intent, without requiring the State to produce forensic evidence such as ballistics matching or trajectory analysis. Prosecutors can rely on a defendant’s own post-incident admissions, eyewitness identification, and conduct after the shooting to establish the mens rea required for murder — a meaningful reminder that informal statements to family members can be decisive evidence even when later disavowed.
The opinion also illustrates the interplay between transferred intent and self-defense in gang-related shooting cases. Even where a defendant presents a plausible self-defense narrative, a jury is free to reject it based on credibility assessments and circumstantial evidence of guilt. Defense attorneys handling similar cases should be alert to the weight courts place on post-offense conduct — flight, weapon disposal, and admissions — as corroboration of criminal intent.