Heather Rene Cameron v. the State of Texas
CourtTexas Court of Appeals, 13th District
Date FiledAugust 6, 2026
Docket13-26-00158-CR
StatusPublished
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Full Opinion
NUMBER 13-26-00158-CR
COURT OF APPEALS
THIRTEENTH DISTRICT OF TEXAS
CORPUS CHRISTI – EDINBURG
HEATHER RENE CAMERON, Appellant,
v.
THE STATE OF TEXAS, Appellee.
ON APPEAL FROM THE CRIMINAL DISTRICT COURT NO. 4
OF TARRANT COUNTY, TEXAS
MEMORANDUM OPINION
Before Chief Justice Tijerina and Justices Silva and Cron
Memorandum Opinion by Justice Cron
Appellant Heather Rene Cameron entered an open plea of guilty to one count of
theft of property with a value between $30,000 and $150,000, a third-degree felony. See
TEX. PENAL CODE § 31.05(a), (e)(5). The trial court found Cameron guilty and sentenced
her to eight years in prison. See id. § 12.34(a). By a single issue, Cameron complains
that her sentence is grossly disproportionate to the offense she committed, and, therefore,
constitutionally infirm under the Eighth Amendment. She asks that we reverse her
sentence and remand for a new punishment hearing. We affirm. 1
I. BACKGROUND
It is undisputed that over the course of thirteen months, Cameron stole a total of
$120,468.74 from her longtime employer, a small business owned by David and Juli
Tierney. Cameron, who was the company’s bookkeeper for approximately twenty-six
years, perpetrated the crime by writing forty-one fraudulent checks to herself during the
relevant period.
After Cameron entered her guilty plea, the trial court deferred a finding on guilt and
requested a presentence investigation (PSI) report. See TEX. CODE CRIM. PROC. art.
42A.252. The PSI report was prepared by supervision officer Edward Sas, and both
Cameron and the Tierneys participated in the process by answering Sas’s questions and
supplying him with supporting documents.
At the subsequent adjudication hearing, the trial court announced that it had
“thoroughly reviewed” the 35-page report, which was the only evidence offered or
admitted at the hearing. The parties focused on the contents of the report during the
hearing, with each side highlighting portions they felt supported their preferred disposition.
For instance, Cameron argued she was a good candidate for community supervision
1 This appeal was transferred to us from the Second Court of Appeals in Fort Worth pursuant to a
docket-equalization order issued by the Supreme Court of Texas. See TEX. GOV’T CODE §§ 22.220(a)
(delineating the jurisdiction of appellate courts), 73.001 (granting the supreme court the authority to transfer
cases from one court of appeals to another at any time that there is “good cause” for the transfer). We are
bound by the transferring court’s precedent to the extent that it differs from our own. See TEX. R. APP. P.
41.3.
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because, as the report noted, she “appears capable of completing a term of probation
successfully”; the fifty-two-year-old had “no prior criminal history”; her risk assessment
showed a “low” chance of recidivism at only 8%; she took some “responsibility for her
crime” by pleading guilty and “providing details about her actions in its commission”; she
“has a history of volunteerism, and has numerous ties to the community”; she was
gainfully employed at the time of the hearing, including a fulltime job as a bookkeeper and
another parttime job; and she “has the support of her family,” some of whom had written
letters of support that were attached to the report. The report also noted that Cameron
“suffer[s] from very serious health problems” that “require constant care, medications, and
maintenance.” Sas expressed concern that if Cameron were imprisoned, it would “be
difficult to replicate” the level of care she was receiving from her numerous specialists.
However, the report also listed factors that, in Sas’s opinion, weighed against
community supervision. Sas considered the crime “egregious” because, among other
reasons, Cameron and “[t]he victims were practically family,” and her actions represented
a “betrayal” that caused significant emotional and financial harm to the Tierneys. In terms
of the financial harm, Sas explained that Cameron initially offered the Tierneys $30,000
in restitution if they agreed not to pursue charges, an offer the Tierneys rejected. He also
noted that, despite her new employment, Cameron had not repaid any amount during the
pendency of the case and that her willingness to do so was conditioned upon her receiving
community supervision. In this regard, Sas felt that Cameron had not fully accepted
responsibility for her actions. Sas also found unconvincing some of Cameron’s
explanations for why she broke bad at age fifty. For example, Cameron explained that
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she had been in an abusive relationship for roughly ten years prior to the offense, but Sas
noted that the relationship ended several years before Cameron began stealing from the
company. Sas also found that Cameron used most of the stolen money, not to pay
outstanding bills, but to make “hundreds upon hundreds” of “frivolous purchases.” He
detailed how the frequency of her online shopping dramatically escalated during the
relevant period and surmised that Cameron “was a person addicted to a lifestyle.” Finally,
with respect to Cameron’s medical conditions, he noted that although serious, Cameron
was currently “working two jobs, including one with full-time hours, which is one indicator
her health issues are, at present, chronic rather than completely debilitating.” 2
Sas ultimately concluded that “a taste of incarceration is warranted, as the mere
threat of incarceration did not prevent her offense nor serve as a proper motivator to
provide reasonable restitution during this process.” The State requested “a prison
sentence on the higher end of the range,” and Cameron asked for community supervision,
or in the alternative, a sentence at “the lowest possible range.” The trial court found
Cameron guilty of the charged offense, sentenced her to a prison term of eight years, and
ordered her to pay $120,468.74 in restitution.
Cameron filed a verified motion for new trial arguing, among other things, that her
sentence constituted cruel and unusual punishment because it “was grossly
2 Sas noted that Cameron’s “primary diagnosis is Granulomatosis with Polyangiitis (GPA, formerly
known as Wegener’s Disease)—an autoimmune disease which is difficult to treat (as it appears the body
is, in essence, attacking itself).” He provided a synopsis of the disease from the Mayo Clinic, which
describes GPA as “a rare disease that causes swelling, also called inflammation, of small blood vessels,”
primarily “in the nose, sinuses, throat, lungs and kidneys,” although “it can affect any organ.” According to
that same overview from the Mayo Clinic, “Early treatment can help people live full lives. Without treatment,
the condition can lead to organ damage that sometimes is fatal.”
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disproportionate to the facts of the case and reflected no consideration of mitigative
evidence.” There was no evidence attached to the motion, and the trial court denied the
motion without conducting a hearing. This appeal ensued.
II. STANDARD OF REVIEW & APPLICABLE LAW
The Eighth Amendment’s prohibition on cruel and unusual punishment, made
applicable to the states by the Due Process Clause of the Fourteenth Amendment,
includes sentences that are disproportionate to the crime committed. Solem v. Helm, 463
U.S. 277, 284 (1983); see U.S. CONST. amends. VIII, XIV. A successful challenge to
proportionality is exceedingly rare and requires the sentence be “grossly disproportionate”
to the crime. State v. Simpson, 488 S.W.3d 318, 322–23 (Tex. Crim. App. 2016) (citing
Lockyer v. Andrade, 538 U.S. 63, 73 (2003)). Stated differently, the Eighth Amendment
“does not require strict proportionality between the crime and the sentence.” Id. at 322
(citing Harmelin v. Michigan, 501 U.S. 957, 1001 (1991) (Kennedy, J., concurring)).
Generally, if a sentence is assessed within the legislatively determined range, it will be
deemed constitutional. See Ex parte Chavez, 213 S.W.3d 320, 323–24 (Tex. Crim. App.
2006) (noting that “the sentencer’s discretion to impose any punishment within the
prescribed range [is] essentially ‘unfettered’”). The punishment range for a third-degree
felony is “imprisonment in the Texas Department of Criminal Justice for any term of not
more than 10 years or less than 2 years.” TEX. PENAL CODE § 12.34(a).
Evaluating a claim of gross disproportionality is a two-step process. First, “a court
must judge the severity of the sentence in light of the harm caused or threatened to the
victim, the culpability of the offender, and the offender’s prior adjudicated and
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unadjudicated offenses.” Simpson, 488 S.W.3d at 323 (citing Graham v. Florida, 560 U.S.
48, 60 (2010)). Second, “[i]n the rare case in which this threshold comparison leads to an
inference of gross disproportionality, the court should then compare the defendant’s
sentence with the sentences received by other offenders in the same jurisdiction and with
the sentences imposed for the same crime in other jurisdictions.” Id. (citing Graham, 560
U.S. at 60). A sentence will be deemed cruel and unusual only when “this comparative
analysis validates an initial judgment that the sentence is grossly disproportionate.” Id.
(citing Graham, 560 U.S. at 60). When the record lacks evidence that would allow a court
to conduct a comparative analysis, the appellant has necessarily failed to substantiate
their Eighth Amendment claim. Trevino v. State, 676 S.W.3d 726, 730 (Tex. App.—
Corpus Christi–Edinburg 2023, no pet.) (citing Simpson, 488 S.W.3d at 323, 324);
Hammer v. State, 461 S.W.3d 301, 304 (Tex. App.—Fort Worth 2015, no pet.); see also
Esquivel v. State, No. 13-21-00179-CR, 2022 WL 17492274, at *2 (Tex. App.—Corpus
Christi–Edinburg Dec. 8, 2022, pet. ref’d) (mem. op., not designated for publication)
(“[B]ecause the trial court had no evidence before it that would allow it to engage in the
comparative analysis detailed in Simpson, we cannot conclude it erred by sentencing
Esquivel within the statutory guidelines.”).
III. ANALYSIS
By her sole issue, Cameron argues that there were numerous factors in the PSI
report that made her “the perfect candidate for probation.” She contends that the trial
court “failed to give proper consideration to the mitigative history,” including her “severe
medical condition and her appropriateness for probation.” She also claims that because
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of her “medical condition and the unsuitability and inability of the prison to provide
appropriate medical treatment,” her sentence is “analogous to a death sentence.”
To begin with, we reject Cameron’s argument that she established an Eighth
Amendment claim based on inadequate medical care before she ever stepped foot in
prison. To be sure, the Eighth Amendment imposes an obligation on prison officials to
guarantee that inmates like Cameron receive “adequate” medical care. Farmer v.
Brennan, 511 U.S. 825, 832 (1994). But to prevail on a claim of inadequate medical care
under the Eighth Amendment, a prisoner must show that prison officials have been
deliberately indifferent to their serious medical needs. Id. at 835. Sas’s mere concern that
Cameron may not receive the same level of medical care in prison, even if well-founded,
does not establish that her care will be constitutionally inadequate. See id.; Kosilek v.
Spencer, 774 F.3d 63, 82–83 (1st Cir. 2014) (explaining that the Eighth Amendment “does
not impose upon prison administrators a duty to provide care that is ideal, or of the
prisoner’s choosing”; instead, it only “proscribes care that is so inadequate as to shock
the conscience” (citation modified)). His generalized concern does not establish “a
substantial risk of serious injury” to Cameron based on the “current attitudes and conduct”
of prison officials. Farmer, 511 U.S. at 845, 847. And it certainly does not establish that
Cameron’s sentence is tantamount “to a death sentence,” as she suggests. Simply put,
her claim of potentially inadequate medical care is entirely speculative.
Moreover, Cameron has pointed us to no authority standing for the proposition that
Cameron’s medical conditions, which have no bearing on the harm she caused or her
culpability, could give rise to a claim of gross disproportionately. See Simpson, 488
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S.W.3d at 323. Essentially, Cameron would rather we “judge the severity of the sentence
in light of” her medical issues, rather than the factors outlined in Simpson. Id. But suffering
from a medical condition, even a serious one, does not exempt an offender from being
imprisoned for their crime. Cf. United States v. Bates, 784 F. App’x 312, 335 (6th Cir.
2019) (explaining that, under federal sentencing guidelines, “[a]lthough district courts may
rely on age and poor health to support a below-guidelines sentence in exceptional cases,
the elderly do not have a license to commit crime, and adequate medical care is available
in federal prisons” (citation modified)). To the extent that Cameron’s medical conditions
are “normatively relevant to [a factfinder’s] determination of a proper punishment,” Beham
v. State, 559 S.W.3d 474, 484 (Tex. Crim. App. 2018), we fail to see how the trial court’s
discretionary decision to give greater weight to other normative facts and assess
punishment within the legislatively prescribed range makes her sentence grossly
disproportionate to the crime she committed. See Ex parte Chavez, 213 S.W.3d at 323–
24.
But even if we assumed, based on the entire record, that this was one of the
exceedingly rare cases that gave rise to an inference of gross disproportionality,
Cameron’s claim would nevertheless fail because there is no evidence in the record that
would allow us (or the trial court) to conduct a comparative analysis. See Trevino, 676
S.W.3d at 730; Hammer, 461 S.W.3d at 304. Accordingly, Cameron’s issue is overruled.
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IV. CONCLUSION
We affirm the judgment of conviction.
JENNY CRON
Justice
Do not publish.
TEX. R. APP. P. 47.2(b).
Delivered and filed on the
6th day of August, 2026.
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