Beyond the Bleach: Using ‘Woods’ to Prove Intentional Family Violence and Admit Graphic Injury Evidence
Woods v. State, 05-24-01305-CR, February 20, 2026.
On appeal from the Criminal District Court No. 2, Dallas County
Synopsis
The Court of Appeals affirmed a murder conviction, holding that a defendant’s post-offense conduct—specifically the use of bleach to sanitize a crime scene, the disposal of the body, and flight from law enforcement—constitutes legally sufficient evidence of “intentional or knowing” conduct. Furthermore, the Court clarified that a defendant is not entitled to a lesser-included offense instruction for manslaughter or criminally negligent homicide when the record contains no evidence that would permit a rational jury to find the defendant acted with only a reckless or negligent mens rea.
Relevance to Family Law
While Woods is a criminal homicide appeal, its implications for Texas family law litigators are profound, particularly in the context of protective orders under Title 4 of the Texas Family Code and fault-based divorce rounds. In cases involving “intentional” family violence, the Woods holding reinforces the evidentiary principle that “consciousness of guilt” evidenced by concealment or “cleaning up” a scene can be used to prove the requisite mental state for a family violence finding. For practitioners dealing with high-conflict custody cases where “accidental” injury is alleged, Woods provides a strategic roadmap for using a party’s post-incident behavior to negate claims of “recklessness” and establish “intentional” harm.
Case Summary
Fact Summary
The appellant, Andre Woods, Jr., was indicted for the murder of Iris Franks. Following a “disagreement” regarding payment for services in a motel room, Woods attacked Franks with a box cutter, inflicting fatal wounds to her neck and chest. Post-mortem, Woods was observed on surveillance video dragging the body to his vehicle and subsequently dumping it in a nearby roadway. When police arrived at the motel, they noted an “overpowering odor” of bleach and visible bleach stains outside the room. Upon being spotted by investigators, Woods fled in his vehicle, eventually crashing into a guardrail. Inside the vehicle, officers discovered more bleach and items belonging to the victim. At trial, Woods admitted to the killing but claimed he “lost control” and acted in self-defense, seeking jury instructions on the lesser-included offenses of manslaughter and criminally negligent homicide.
Issues Decided
The Court addressed three primary categories of error: (1) whether the evidence was legally sufficient to prove the appellant intentionally or knowingly caused the death; (2) whether the trial court erred in refusing to submit jury instructions on the lesser-included offenses of manslaughter and criminally negligent homicide; and (3) whether the admission of graphic autopsy photographs violated Texas Rule of Evidence 403.
Rules Applied
The Court applied the Jackson v. Virginia standard for legal sufficiency, viewing all evidence in the light most favorable to the verdict. Regarding intent, the Court relied on Nisbett v. State, which establishes that a factfinder may infer intent from the defendant’s acts, words, and conduct, including attempts to conceal evidence. For the lesser-included offense analysis, the Court utilized the two-prong Royster/Rousseau test, focusing on the second prong: whether there was some evidence in the record that would permit a jury rationally to find that if the defendant is guilty, he is guilty only of the lesser offense. Finally, the Court applied the Rule 403 balancing test for the admission of photographs, considering the number of images, their gruesomeness, and their probative value in illustrating the medical examiner’s testimony.
Application
The Court’s application of the law focused heavily on the “trail of bleach.” The Court reasoned that Woods’s elaborate efforts to sanitize the motel room and his flight from police were inconsistent with an accidental or reckless act. The legal story told by the evidence was one of deliberate concealment, which the Court translated into evidence of a “knowing” mental state. Regarding the jury charge, the Court noted that while Woods testified he “lost control,” he also admitted he was in “full control” during the second half of the attack and deliberately “went for the throat.” Because his own testimony established intentionality rather than mere recklessness (ignoring a known risk) or negligence (failing to perceive a risk), the trial court was not required to provide the “safety valve” of a lesser-included instruction.
Holding
The Court of Appeals affirmed the conviction on all counts. First, the Court held that the evidence of post-offense concealment and the nature of the injuries (throat-slitting) were sufficient for a rational jury to find intentional murder beyond a reasonable doubt.
Second, the Court held that the trial court properly denied the instructions for manslaughter and criminally negligent homicide. The Court reasoned that there was no evidence suggesting Woods acted with a lesser culpable mental state; his testimony indicated a deliberate, albeit emotionally charged, physical assault.
Third, the Court held that the autopsy photographs were admissible. Despite their graphic nature, they were highly probative of the manner of death and the type of weapon used, particularly because they corroborated the medical examiner’s discovery of box cutter fragments embedded in the victim’s trachea.
Practical Application
For the family law litigator, Woods is a lesson in the “Post-Incident Conduct” doctrine. When representing a petitioner in a protective order hearing, use the “bleach” analogy: look for evidence that the respondent attempted to delete text messages, coached children on what to say, or cleaned the physical site of an assault. These actions are not merely “suspicious”—under Woods, they are substantive evidence of the intentionality of the underlying act. Conversely, if defending a client against allegations of “intentional” cruelty in a divorce, the absence of concealment or flight can be framed as evidence of a lack of the requisite mens rea.
Checklists
Establishing Intentionality through Conduct
- Identify Concealment: Did the party attempt to hide physical evidence (cleaning supplies, moving objects)?
- Document Flight: Did the party leave the scene abruptly or avoid law enforcement?
- Analyze Weaponry: Was the “instrument” used (even if a household object) applied in a manner consistent with deliberate harm rather than an accident?
- Assess Sanitization: Is there evidence of “bleaching” the record (deleting digital evidence or social media)?
Defeating Lesser-Included Arguments (Civil Context)
- Review Party Admissions: Did the opposing party admit to “losing control” while simultaneously describing deliberate physical movements?
- Nature of Injuries: Are the injuries so specific or localized that they negate a theory of “recklessness” (e.g., multiple strikes vs. a single push)?
- Consistency of Narrative: Does the evidence show the party was “in control” during any phase of the incident?
Citation
Woods v. State, ___ S.W.3d ___ (Tex. App.—Dallas 2026, no pet. h.) (No. 05-24-01305-CR).
Full Opinion
Family Law Crossover
The Woods opinion is a powerful tool for weaponizing “Consciousness of Guilt” in the trial of a divorce with a “fault” component or a SAPCR involving family violence. Under Texas Family Code § 81.001, a court shall issue a protective order if it finds family violence occurred and is likely to occur in the future. Respondents often argue that an injury was a “reckless accident” to avoid the permanent stigma and firearm restrictions associated with a family violence finding. Woods provides the authority to argue that if a spouse attempts to cover up the “accident”—by cleaning the house, hiding a broken phone, or lying to the pediatrician—that conduct is legally sufficient to elevate the finding from “reckless” to “intentional.” In the property division context, use Woods to argue for a disproportionate share based on “cruelty,” using the same concealment evidence to prove the intentionality of the conduct.
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