Randy Williams v. State Texas

Appellant was convicted in a consolidated trial of the offenses of aggravated kidnapping and aggravated sexual assault and received a life sentence for each offense. Appellant argued that the trial court fundamentally erred in charging the jury at the punishment stage that aggravated kidnapping was a first degree felony. The State and appellant also disputed whether this charge corrupted the jurys punishment consideration of aggravated sexual assault. The court of appeals agreed with the appellants contention that the trial courts instruction amounted to fundamental error, and accordingly reversed and remanded appellants conviction for aggravated kidnapping. See Williams v. State, 718 S.W.2d 772 (Tex.App. - Corpus Christi 1986). However, the court of appeals affirmed the conviction for aggravated sexual assault, concluding that appellant failed to demonstrate how the aggravated kidnapping charge influenced the jurys deliberation of punishment on the aggravated sexual assault. Id., at 775. We granted petitions for discretionary review from both the State and appellant to consider whether the jury instruction that aggravated kidnapping is a first degree felony constituted fundamental error, and whether the aggravated kidnapping jury charge unfairly influenced the jurys assessment of punishment for aggravated sexual assault. Tex.R.App. Pro. 200(c)(2).