Bryan v. State

Fletcher, Presiding Justice.

Sheila Bryan was convicted of malice murder and arson in connection with the death of her mother, Freda Weeks, in a burning car.1 *232Prior to trial, Bryan filed a motion in limine to exclude any evidence that her husband increased his automobile liability insurance three months before the fire. The trial court denied the motion and admitted the evidence. Because our cases require the state to present independent evidence of a nexus between the crime charged and the existence of the insurance policy and the state presented no evidence of a connection, we reverse.

1. The…