Issues Addressed
This case has three issues that both sides have recognized and will look to argue upon. Separating a case into separate issues allows for a clear and more efficient court process as each issue is looked at clearly through a different lens. This can also help to establish which standard of review should apply and what each side needs to prove.
Issue 1:
Whether or not the evidence in the trial was sufficient enough to prove that Marta and David agreed to be informally married​.
Issue 2:
Whether or not the evidence in the trial was sufficient enough to prove that Marta and David presented themselves as a married couple that could be recognized by the community.
Issue 3:
Whether or not the court erred in deciding not to submit the Appellant’s additional jury instructions.
What each side must prove
Appellant - City of Euless
Appellant must prove by a preponderance of evidence that David and Marta were not informally married prior to David’s death.
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Appellant must prove that there was no substantial evidence of an agreement between Marta and David that they were married
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Appellants must prove that there was no substantial evidence of David and Marta presenting themselves as married to their community
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Appellants must prove with substantial evidence that the judges decision to not show the jury the instructions asked for by the appellant was a harmful error. This means that it would have likely changed the outcome of the case.
Appellee - Marta Danylyk
Appellee simply must prove that there was evidence to back the jury’s decision and a reasonable juror could have come to the same conclusion. This applies to both the issue of recognizing an agreement between Marta and David to get married and recognizing the fact that they held themselves out to their community.
Basic Definitions & Components
Common law marriage/informal marriage - In Texas, two people can be married without having an official wedding ceremony or even obtaining a marriage license. This is called a common law marriage. In order for two people to be married under Texas law they must 1.) have an agreement that they are married to each other, 2.) live together after the agreement, and 3.) hold themselves out as a married couple to their community.
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Burden of proof - The burden of proof in a case is which side must prove their argument. In this case, the burden of proof fell on the appellant in trial. This means that the appellant had to create an argument to show conclusively that Marta Danylyk was not an eligible spouse for Office Hofer. The appellee simply had to show that the argument of the other side was invalid. This makes it even more difficult for the appellant to prove on appeal.
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Jury Instructions - Jury instructions are additional pieces of information that are provided to the jury before a trial is held. They are meant to provide information that will help the jury accurately direct their decision. Click here for the jury instructions that the appellant
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Conflicting evidence - Evidence from both sides of the argument that is substantial. This would mean it is up to the jury to decide which argument and which evidence carries more weight. In this case, having conflicting evidence would help the appellee prove that the jury did not make a blatant error in their decision. This is because under the reasonableness/substantial evidence standard, the appellant must prove that no reasonable juror could have come to the conclusion that the jury did. Conflicting evidence shows that both sides had weight to their argument which means the jury decision cannot be overturned under the reasonableness/substantial evidence standard.
Standard of Review
Holiday Sale
In this case the standard of review for all three issues was reasonableness/substantial evidence. This means the appellant must prove to the appellate court that the case did not have any substantial evidence that could have led a reasonable juror to come to the verdict that they did. The court uses a 2 stage test to come to a conclusion. They will first look for any reasonable evidence to support the initial ruling. If this is found the initial ruling will be upheld. If it is not found they will then look into evidence that proves the ruling was legally incorrect. If this is met they would overturn the initial ruling. This is a difficult standard for the appellant to meet.
Opinion of the Court
The appellate court ruled in favor of Danylyk in this case. They concluded that the evidence in the case was sufficient to support the jury verdict and concluded that the trial court did not err by refusing to present the City of Euless’ jury instructions to the jury. The appellate court also denied the appellant’s motion for rehearing.
Options for the Appellate
The City of Euless is now left with two options: they can file a motion for rehearing en banc in front of the entire Dallas Court of Appeals or they can petition for review to the Texas Supreme Court.