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Patrick Anthony Currie v. the State of Texas

2026-08-21

Summary

Holding. The trial court properly denied the defendant's request for a jury instruction on misdemeanor assault family violence as a lesser-included offense of felony assault family violence by impeding breath or circulation, because misdemeanor assault does not qualify as a lesser-included offense under Texas law when the injury element differs. The judgment is affirmed.

Patrick Anthony Currie was convicted of felony assault family violence by impeding breath or circulation, enhanced by his habitual felony offender status, and sentenced to fifty years in prison. At trial, Currie requested a jury instruction on the lesser-included offense of misdemeanor assault family violence, arguing that the jury could rationally find he caused bodily injury without necessarily finding that he applied pressure to the victim's throat or neck. The trial court denied this request, and the final jury charge did not include the lesser-included offense instruction.

On appeal, Currie challenged the trial court's denial of his requested instruction. The court analyzed whether misdemeanor assault family violence—which requires proof of intentional, knowing, or reckless bodily injury—qualifies as a lesser-included offense of felony assault family violence by impeding breath or circulation. Under controlling precedent, a bodily-injury assault is not a lesser-included offense of occlusion assault (impeding breath or circulation) when the disputed element is the type of injury, because the specific injury of impeding normal breathing is distinct from and exclusive of other bodily injuries. The court concluded that the two offenses require different factual proof and therefore the lesser-included offense instruction was not legally warranted.

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

Key issues

  • Whether misdemeanor assault family violence is a lesser-included offense of felony assault by impeding breath or circulation
  • Whether the statutory injury requirements of occlusion assault preclude instruction on non-impeding bodily injury assault
  • Preservation and harmless error analysis for unpreserved jury charge error

Procedural posture

Currie appealed his conviction for felony assault family violence by impeding breath or circulation to the Texas Court of Appeals, Thirteenth District, challenging the trial court's denial of a lesser-included offense jury instruction.

Authorities cited

Opinion

majority opinion

NUMBER 13-26-00057-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

PATRICK ANTHONY CURRIE, Appellant,

v.

THE STATE OF TEXAS, Appellee.

ON APPEAL FROM THE 221ST DISTRICT COURT

OF MONTGOMERY COUNTY, TEXAS

MEMORANDUM OPINION

Before Chief Justice Tijerina and Justices Silva and Cron

Memorandum Opinion by Justice Silva

Appellant Patrick Anthony Currie was convicted of assault family violence by

impeding breath or circulation, a third-degree felony enhanced by his habitual felony

offender status. See TEX. PENAL CODE §§ 12.42(d), 22.01(b)(2)(B). On appeal, Currie

solely contends the trial court abused its discretion by denying his request for a jury

instruction on the lesser-included offense of misdemeanor assault family violence. We affirm.

I. BACKGROUND 1

On November 6, 2025, Currie was charged in a superseding indictment for

committing the above-referenced offense. The superseding indictment contained two

enhancement paragraphs alleging that he was previously convicted of two felony

offenses. A jury trial commenced on November 17, 2025, and Currie proceeded with his

case pro se. At trial, Caitlin Mayberry testified that at the time Currie physically assaulted

her she was in a dating relationship with him. She further testified that during the assault

he impeded her ability to breathe by placing his forearm around her neck.

Before the State rested its case-in-chief, the trial court conducted a charge

conference outside the presence of the jury and the following exchange occurred:

[Currie]: I would just like [to] add a couple things, a lesserincluded, if impeding breath cannot be proven, of

assault and—

THE COURT: You are supposed to write it out and ask me to put in

whatever—you need to tell me what you want me to

put in and where you want me to put it, and then, I will

let the State respond, but I have this down. So, we will

discuss this later. We are not at the point where we are

charging the jury.

THE COURT: What says the State on the lesser[-]included?

[The State]: The Court can correct me if I’m wrong, but assault

family violence misdemeanor is not a lesser of assault

family violence strangulation. So, [the State] would

1 This case is before the Court on transfer from the Ninth Court of Appeals pursuant to a docketequalization order issued by the Supreme Court of Texas. See TEX. GOV’T CODE §§ 22.220(a) (delineating the jurisdiction of appellate courts), 73.001 (granting the supreme court the authority to transfer cases from one court of appeals to another at any time that there is “good cause” for the transfer). We are bound by the precedent of the transferring court to the extent that it differs from our own. See TEX. R. APP. P. 41.3.

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object to it being in the jury charge.

THE COURT: It’s not, and I haven’t heard anything that would warrant

that at this time.

[Currie]: If the elements of impeding breath cannot be proven,

would that not lead to the lesser of assault?

THE COURT: No, not necessarily, because it’s a separate offense.

Not every offense is a lesser included of another

offense. It’s kind of a complicated area of the law, but I

will look at it and your request and I understand why

you brought it up. That’s, actually, a very fair thing for

you to say. In fact, I’m impressed that you have done

your homework and looked at it. So, I think that’s—

normally, I would say that it would be, but I don’t think,

in this situation, it is, but I’m going to have to look at it

and see.

After both parties rested, the trial court asked the parties whether they had any

objections to the proposed jury charge, and Currie responded, “No objection.” 2 The jury

returned a guilty verdict, and Currie elected for the trial court to impose his sentence.

Currie pleaded true to the State’s two enhancement paragraphs, and the trial court found

them to be true and sentenced him to fifty years’ imprisonment. This appeal followed.

II. STANDARD OF REVIEW AND APPLICABLE LAW

A. Charge Error

“The purpose of the trial court’s jury charge is to instruct the jurors on all of the law

applicable to the case.” Cortez v. State, 469 S.W.3d 593, 598 (Tex. Crim. App. 2015);

see TEX. CODE CRIM. PROC. art. 36.14. In analyzing an alleged jury charge error, our first

duty is to determine whether error exists. Ngo v. State, 175 S.W.3d 738, 743 (Tex. Crim.

2 We note that the record before us does not indicate that the trial court ruled on Currie’s request

for a lesser-included offense instruction; however, the final jury charge did not include said instruction.

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App. 2005). If we find error, we then analyze that error for harm. Reed v. State, 680

S.W.3d 620, 625 (Tex. Crim. App. 2023). The degree of harm necessary for reversal

depends on whether the error was preserved. Jordan v. State, 593 S.W.3d 340, 346 (Tex.

Crim. App. 2020) (citing Almanza v. State, 686 S.W.2d 157, 171 (Tex. Crim. App. 1985));

Hernandez v. State, 533 S.W.3d 472, 481 (Tex. App.—Corpus Christi–Edinburg 2017,

pet. ref’d).

If there is error and the defendant preserved the alleged error, then we must

reverse if we find “some harm.” Jordan, 593 S.W.3d at 346; Almanza, 686 S.W.2d at 171.

But when the jury charge error is not preserved, the Court will reverse only upon a

showing of “‘egregious harm,’ which occurs when the error created such harm that the

appellant was deprived of a fair and impartial trial.” Chambers v. State, 580 S.W.3d 149,

154 (Tex. Crim. App. 2019) (citing Villarreal v. State, 453 S.W.3d 429, 433 (Tex. Crim.

App. 2015)); Almanza, 686 S.W.2d at 171. “Errors that result in egregious harm are those

that affect ‘the very basis of the case,’ ‘deprive the defendant of a valuable right,’ or ‘vitally

affect a defensive theory.’” Gonzalez v. State, 610 S.W.3d 22, 27 (Tex. Crim. App. 2020)

(quoting Ngo, 175 S.W.3d at 743). When considering whether a defendant suffered

egregious harm, we must consider: (1) the entire jury charge; (2) the state of the

evidence, including the contested issues and weight of probative evidence; (3) the

argument of counsel; and (4) any other relevant information revealed by the record of the

trial as a whole. Id.; Almanza, 686 S.W.2d at 171.

B. Lesser-Included Offense

Courts generally use a two-pronged test to determine whether a defendant is

entitled to a jury charge instruction on a lesser-included offense. Chavez v. State, 666

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S.W.3d 772, 776 (Tex. Crim. App. 2023). The first step of the analysis asks the purely

legal question of whether the lesser-included offense is included within the proof

necessary to establish the offense charged. Id.; see TEX. CODE CRIM. PROC. art. 37.09. If

that prong is satisfied, the second step is to determine whether there exists “evidence

from which a rational jury could find the defendant guilty of only the lesser offense.”

Chavez, 666 S.W.3d at 776. Anything more than a scintilla of evidence will be sufficient

to entitle a defendant to a charge on the lesser offense. Id. Meeting this threshold requires

more than mere speculation—it requires affirmative evidence directly germane to the

lesser-included offense that provides the lesser-included offense as a valid, rational

alternative to the greater offense. Id. “[I]t is not enough that the jury may disbelieve crucial

evidence pertaining to the greater offense, but rather there must be some evidence

directly germane to the lesser-included offense for the finder of fact to consider before an

instruction on a lesser-included offense is warranted.” Ransier v. State, 670 S.W.3d 646,

650 (Tex. Crim. App. 2023) (alteration in original) (quoting Bullock v. State, 509 S.W.3d

921, 925 (Tex. Crim. App. 2016)).

A person commits felony assault family violence by impeding breath or circulation

if the person intentionally, knowingly, or recklessly impedes the normal breathing of a

person by applying pressure to the person’s throat or neck or by blocking the person’s

nose or mouth. See TEX. PENAL CODE § 22.01(b)(2)(B); Ortiz v. State, 623 S.W.3d 804,

805 (Tex. Crim. App. 2021) (referring to Section 22.01(b)(2)(B) as “occlusion assault”).

On the other hand, a person commits misdemeanor assault family violence by

intentionally, knowingly, or recklessly causing bodily injury to another person. TEX. PENAL

CODE § 22.01(a)(1). For assault to be a family violence offense, the victim must be a

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person whose relationship to or association with the defendant is described by Sections

71.0021(b), 71.003, or 71.005 of the Texas Family Code, which includes, as relevant

here, a dating relationship. TEX. FAM. CODE §§ 71.0021(b), 71.003, 71.005.

III. ANALYSIS

Currie argues “that misdemeanor assault family violence is established by proof of

the same or less than all the facts required to prove the charged felony.” He points out

the jury could have rationally found he “caused bodily injury to a dating partner

(misdemeanor) without finding that he applied pressure to her throat or neck (felony).” He

asserts that “[w]ithout the lesser-included option, the jury faced a binary choice—convict

of the felony or acquit entirely—even though the evidence permitted a middle ground.”

Contrary to his contentions, however, the Texas Court of Criminal Appeals

provides direct guidance on whether the lesser-included offense of bodily injury assault

is included within the proof necessary to establish the offense Currie was alleged to have

committed—assault family violence by impeding breath or circulation. See Ortiz, 623

S.W.3d at 805. Notably, “bodily-injury assault is not a lesser-included offense of occlusion

assault when the disputed element is the injury because the statutorily specified injury of

impeding normal breathing or blood circulation is exclusive of other bodily injuries.” Id.

The Ortiz court reasoned that “non-impeding injuries are not included in occlusion assault

because they are not proven by the same or less facts than required to prove occlusion

assault; they are proven by different, additional facts.” Id. at 808–09.

Here, Currie is primarily challenging the element concerning Mayberry’s injury.

Because of this, misdemeanor assault family violence does not qualify as a lesserincluded offense of felony assault family violence by impeding breath or circulation. See

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id. at 805. 3 Thus, Currie’s requested instruction is not legally plausible because it is not

included within the proof necessary to establish the offense of which he was charged.

See id. at 810 (“Occlusion assault’s focus on a narrowly defined injury forecloses an

instruction on an assault that results in a different injury.”); Chavez, 666 S.W.3d at 776.

Consequently, we need not address the remaining prong of the lesser-included offense

analysis. See Chavez, 666 S.W.3d at 776.

In this regard, the trial court was not required to instruct the jury on the requested

instruction where the conduct establishing the lesser-included offense is not included

within the conduct charged. See Irving v. State, 176 S.W.3d 842, 846 (Tex. Crim. App.

2005). Accordingly, the trial court did not commit error when it denied Currie’s request

that a lesser included offense instruction for misdemeanor assault family violence be

included in the jury charge. Ngo, 175 S.W.3d at 743. We overrule Currie’s sole issue.

IV. CONCLUSION

We affirm the trial court’s judgment.

CLARISSA SILVA

Justice

Do not publish.

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

Delivered and filed on the

21st day of August, 2026.

3 We note that there may be an instruction for a lessor-included offense of misdemeanor assault

in an occlusion assault case under very specific circumstances that are not present here. For instance, “if the relationship is at issue, then an instruction on misdemeanor assault may be warranted.” Ortiz v. State, 623 S.W.3d 804, 808 (Tex. Crim. App. 2021); see, e.g., Garcia v. State, No. 07-23-00420-CR, 2024 WL 3682792, at *3 (Tex. App.—Amarillo Aug. 6, 2024, pet. ref’d) (mem. op., not designated for publication) (finding the first prong of lesser-included analysis satisfied because appellant raised an issue about the relationship between himself and the victim).

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