David Len Moulton v. State
David Len Moulton was convicted of murdering his wife, Rebecca Moulton, and sentenced to sixty years' imprisonment. The conviction was appealed on several grounds, including an erroneous jury charge. The Sixth Appellate District of Texas at Texarkana found that the trial court's jury charge, which included "asphyxiation by manner and means unknown" when the manner and means were "unknowable" (i.e., multiple known options were presented by evidence), was erroneous. The court determined this error caused "some harm" to Moulton, especially considering the State's closing argument focused on the "manner and means unknown" allegation coupled with suffocation testimony. Consequently, the court reversed the trial court's judgment and remanded the case for further proceedings.