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Willie Maxwell v. the State of Texas

2026-08-18

Summary

Holding. The trial court did not abuse its discretion in denying the motion for mistrial where a prompt instruction to disregard cured any prejudicial effect from the officer's statement regarding charges based on prior offenses, the misconduct was not severe, and strong evidence of guilt existed independent of the challenged testimony. The judgment of conviction is affirmed.

Willie Maxwell was convicted of robbery after a December 2023 incident at a Dollar General store where he threatened an employee, took items, and punched her in the face. During trial, a police officer testified on redirect examination that Maxwell was arrested for aggravated robbery, theft with previous convictions, and resisting arrest. The defense objected under rules barring character evidence and improper questioning, and the trial court sustained the objection and instructed the jury to disregard the statement. Maxwell appealed, arguing the trial court abused its discretion by denying his motion for mistrial based on this testimony.

The appellate court affirmed, applying a three-factor test to determine whether the error was incurable. The court found the misconduct was not severe because the officer's statement was the only mention of extraneous offenses, with no supporting details or evidence presented. The trial court's prompt instruction to disregard cured any potential harm, and the conviction rested on substantial evidence from multiple witnesses beyond the challenged testimony. The court concluded this was not an extreme circumstance warranting mistrial, as the error was curable through the jury instruction.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether eliciting testimony about extraneous offenses through an improper question warrants mistrial
  • Whether a jury instruction to disregard cures prejudicial testimony regarding prior charges
  • Application of the three-factor Mosley test for evaluating mistrial motions

Procedural posture

This appeal came to the Thirteenth District Court of Appeals from the Criminal District Court No. 3 of Tarrant County following Maxwell's conviction and sentencing for robbery with a twenty-five-year prison sentence.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

NUMBER 13-24-00597-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

WILLIE MAXWELL Appellant,

v.

THE STATE OF TEXAS Appellee.

ON APPEAL FROM THE CRIMINAL DISTRICT COURT NO.3

OF TARRANT COUNTY, TEXAS

MEMORANDUM OPINION

Before Justices Peña, West, and Fonseca

Memorandum Opinion by Justice Peña

Appellant, Willie Maxwell, 1 was convicted of robbery, a second-degree felony. See

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TEX. PENAL CODE § 29.02. The trial court found a punishment enhancement paragraph

1 The indictment and other filings associated with this cause number also identify the appellant as

Willie Maxwell Jr.

true and sentenced him to twenty-five years’ confinement. Appellant raises one issue on

appeal, arguing the trial court erred when it denied his motion for mistrial. We affirm.

I. BACKGROUND 2 1F

A. Offense

On February 21, 2024, a grand jury indicted appellant for intentionally or knowingly

threatening or placing Adell Brumfield in imminent fear of bodily injury or death while in

the course of committing theft. See id. § 29.02(a)(2). At trial, the evidence showed that on

December 26, 2023, appellant visited a Dollar General where Brumfield was working as

a manager. Brumfield observed signs that appellant was intoxicated and asked him to

leave. Shortly after, appellant returned and Brumfield saw him trying to hide and take

items from the store. Brumfield asked him to return the items, but he refused and

threatened her by saying he would “fight[] back.” After Brumfield tried to deescalate the

situation, appellant punched her in the face.

B. Challenged Questioning

The State called five witnesses during the guilt phase. Pertinent here, the State

called Officer Stephanie Lopez, who gave her account of the incident as a responding

officer. Regarding the charge appellant was arrested for in the present case, the following

questioning transpired on cross-examination:

[DEFENSE]: —the arrest for the charge involving Adell Brumfield

was theft?

[OFFICER LOPEZ]: Correct.

[DEFENSE]: I pass the witness.

2 This case is before this Court on transfer from the Second Court of Appeals in Fort Worth pursuant

to a docket-equalization order issued by the Supreme Court of Texas. See TEX. GOV’T CODE §§ 22.220(a), 73.001.

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THE COURT: Redirect.

Immediately after, the State questioned Officer Lopez on re-direct examination:

[STATE]: So, Officer Lopez, the arrest for the Defendant, what

was he arrested for, just to make it clear to the jury?

[OFFICER LOPEZ]: The Defendant was arrested for aggravated robbery,

theft with previous convictions,—

[DEFENSE]: Objection.

[OFFICER LOPEZ]: —resisting arrest and transport—

[DEFENSE]: Objection. Your Honor, under 403, under 404(b), I

object to the statement made by the witness.

THE COURT: All right. This objection is sustained.

[DEFENSE]: And I request that a mistrial be granted in this case

because of the statement that was uttered.

THE COURT: Do you wish an instruction to disregard?

[DEFENSE]: Yes.

The trial court instructed the jury to disregard Officer Lopez’s statement and denied

appellant’s motion for mistrial. The jury found appellant guilty of robbery, and the trial court

sentenced him to twenty-five years’ confinement. On direct appeal, appellant argues that

the trial court abused its discretion in denying his motion for mistrial.

II. DISCUSSION

A. Standard of Review and Applicable Law

We review a trial court’s decision to grant or deny a motion for mistrial for an abuse

of discretion. Hallman v. State, 721 S.W.3d 307, 313 (Tex. Crim. App. 2025); Archie v.

State, 221 S.W.3d 695, 699 (Tex. Crim. App. 2007). In reviewing a trial court’s ruling on a

motion for mistrial, we must uphold the trial court’s ruling if it was within the zone of

reasonable disagreement. Hallman, 721 S.W.3d at 313.

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“Ordinarily, a prompt instruction to disregard will cure error associated with an

improper question and answer, even one regarding extraneous offenses.” Irsan v. State,

708 S.W.3d 584, 614 (Tex. Crim. App. 2025) (quoting Ovalle v. State, 13 S.W.3d 774, 783

(Tex. Crim. App. 2000)). “Mistrial is appropriate for only ‘highly prejudicial and incurable

errors.’” Id. (quoting Simpson v. State, 119 S.W.3d 262, 272 (Tex. Crim. App. 2003)). In

determining whether a mistrial should have been granted, we apply the test set out in

Mosley, which balances three factors: “(1) severity of the misconduct (the magnitude of

the prejudicial effect of the prosecutor’s remarks), (2) measures adopted to cure the

misconduct (the efficacy of any cautionary instruction by the judge), and (3) the certainty

of conviction absent the misconduct (the strength of the evidence supporting the

conviction).” Hallman, 721 S.W.3d at 313–14 (quoting Mosley v. State, 983 S.W.2d 249,

259 (Tex. Crim. App. 1998)). “Only in extreme circumstances, where the prejudice is

incurable, will a mistrial be required.” Archie, 221 S.W.3d at 699 (quoting Hawkins v. State,

135 S.W.3d 72, 77 (Tex. Crim. App. 2004)). “The determination as to whether a given

error calls for a mistrial must be made by examining the peculiar facts and circumstances

of each case.” Hallman, 721 S.W.3d at 313 (quoting Hernandez v. State, 805 S.W.2d 409,

414 (Tex. Crim. App. 1990).

B. Motion for Mistrial

Appellant argues that the trial court abused its discretion when it denied his motion

for mistrial based on Officer Lopez’s testimony regarding the charged offense. Appellant

specifically challenges the State’s questioning on re-direct examination of Officer Lopez,

wherein she stated that appellant was arrested for “aggravated robbery, theft with

previous convictions,” and “resisting arrest and transport.” Appellant contends that the

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jury was unfairly prejudiced when the State elicited testimony that appellant’s charge in

the current case was predicated on extraneous offenses, and the trial court erred to permit

the State’s questioning.

As widely recognized, the asking of an improper question alone will seldom call for

a mistrial, and any harm from such a question will in most cases be cured by an instruction

to disregard the question. Hernandez, 805 S.W.2d at 413–14. First, as to the severity of

the alleged misconduct, the matter regarding the reason for arrest and charged offense

was first raised on cross-examination by defense counsel. Though Officer Lopez testified

that appellant’s arrest was based in part on prior extraneous offenses, no further

testimony, documents, or other evidence was ever put forth before the jury regarding the

extraneous offenses. See id. The State did not offer any details about any extraneous

offense and offered no proof aside from Officer Lopez’s testimony as to whether those

convictions had occurred. See id. at 413; Irsan, 708 S.W.3d at 614.

Second, the trial court followed with a prompt instruction to the jury to disregard

the challenged portion of Officer Lopez’s testimony. See Irsan, 708 S.W.3d at 614; Ovalle,

13 S.W.3d at 783–84; Hernandez, 805 S.W.2d at 413–14. Appellant points to nothing in

the record indicating the jury failed to comply with this instruction and did not challenge

its substantive sufficiency. See Reed v. State, 680 S.W.3d 620, 627 (Tex. Crim. App. 2023)

(“We generally presume that the jury followed the trial court’s instructions.”).

Lastly, the jury heard from multiple witnesses and the State admitted evidence

supporting the strength of the conviction aside from the challenged testimony. Overall,

the record weighs against the magnitude of any potential prejudicial effect, reflects

effective measures to cure, and shows ample evidence to support the conviction. See

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Hallman, 721 S.W.3d at 313–14. This case does not present an “extreme circumstance”

where the alleged prejudice is incurable. See Archie, 221 S.W.3d at 699.

We conclude the trial court did not abuse its discretion in denying appellant’s

motion for mistrial. We cannot say that the challenged questioning was “so ‘highly’ and

‘clearly’ prejudicial as to leave an indelible impression on the jurors’ minds” such that a

mistrial was warranted. Irsan, 708 S.W.3d at 614. Thus, the trial court acted within its

discretion and we overrule appellant’s sole point of error.

III. CONCLUSION

We affirm the judgment of conviction.

L. ARON PEÑA JR.

Justice

Do not publish.

TEX. R. APP. P. 47.2(b).

Delivered and filed on the

18th day of August, 2026.

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