The State of Texas vs A. A. Spangler

In the District Court of Clay County, Texas, Spring term, 1900

Be it remembered that on the trial of the above entitled cause after the Defendant A. A. Spangler had testified for himself on direct examination, the State's counsel on cross examination, asked him why he had turned over to Mrs. Whitesides the triangle cattle, to which he answered: "I was holding Walter's money for him, and she (the deceased) was after me for it, together with what I owed her, and I turned them cattle over on that indebtedness." Q. Did you turn over all you had of that brand at that time? A. "Yes, sir; then right on top of that I was attached here. I had got in debt some five or six thousand dollars, and they went and attached about twenty thousand dollars worth of stuff here to pay off that indebtedness, and then attached all the cattle they could get their hands on, but there was some remnant stuff they did not get their paws on, and as I would get them up I would turn them in to her. "(deceased)

And be it further remembered that after the witness, Charlie Spangler had testified for the State on cross examination he was asked by Defendant's counsel the following question, viz: Q. I will asked you now if you ever heard her, (Mrs. Whitesides) say anything about your mother or sisters? A. Yes sir; she said they were God damned whores.

And be it further remembered that on the argument of the case State's counsel frequently asked why it was if the deceased was such a bad woman Defendant had left his home and family, and was living on the Leonard place with the deceased; and in answering such argument Defendant's counsel referred to the fact that he, Defendant, had been broken up by attachments. And he proposed to argue the testimony of the Defendant, Spangler, drawn out on cross examination by the State with reference to such attachments, which testimony is above set out. To which proposed argument State's counsel objected and insisted that no such evidence had been adduced on the trial, which objections were sustained by the Court and Defendant's counsel were not permitted to refer to and argue the such testimony. To which action of the Court these Defendants then and there excepted.

Thereafter Defendant's counsel, in discussing the character of the deceased, and her animosity toward Defendant and his family, began making reference to the testimony of the witness, Charlie Spangler, which is above set out.

Whereupon State's counsel again object to such argument and insisted that no such evidence had been adduced on the trial, and the Court sustained the objections and refused to permit such testimony to be referred to in the argument. To which action of the Court the Defendant then and there excepted, and he now here tenders this his bill of exceptions to said ruling and asks that same be approved, which is done.

DEFENDANT'S EXCEPTIONS:


Testimony of L. R. Smith:

Q. What was Spangler's manner, how did he look and appear when he came along, did he seem to be mad or not?
A. It seemed to me like ---
Defendant objected to the statement as to whether or not he seemed mad, as being a conclusion of the witness, and he out to describe what defendant did, and not what he seemed to him.
Objection overruled. Defendant excepted.
Q. What was his manner, just describe it.
A. Well, I thought he looked mighty pale and haggard, it seemed as if there was some trouble some way or another, but of course me not knowing anything about any trouble ---
Defendant objected.
Q. Just state how he looked, not what you thought.

Same witness:
Q. Well, did Mrs. Whiteside remain there (at the barn), or did she go off somewhere?
A. Well, she stayed there some few minutes after that, and remarked she was going to take her calves ---
Defendant objected.
Q. Did she seem to be uneasy about anything or not?
Defendant objected to the question, on the ground that it calls for a conclusion, is leading and hearsay.
THE COURT: If he is describing her manner he can do so.
Objection overruled. Defendant excepted.
Q. What was her manner?
A. Well, as to her manner, from the way she talked she seemed to be uneasy.
Objected to, as being a conclusion. Defendant objects to the witness giving an opinion about the woman, based upon her declaration made to him when the defendant was not present.
Object overruled. Defendant excepted.

Same witness, cross examination:
Q. Haven't you stated in answer to Mr. Davis that you saw no weapon until after you laid the woman in the house, and that Frank went after Walter and that you found the pistol?
THE COURT: The jury will say as to that.
Defendant excepted, on the ground that they have a right to know whether he stated it or not, and have a right to have in the record the witness' answer to that question, unless it is an illegal question.
The state objected on the ground that the court and jury know the witness' testimony.
THE COURT: If you did not understand the witness' testimony I will permit the witness to answer.
MR. HODGES: Don't worry about my understanding it.
Q. Do you now state that you saw the pistol as you carried the woman into the room where she was shot?
A. I think I did.
Q. Did you state in your examination in chief that you saw the pistol after Frank went after his brother Walter?
Objected to by the state, on the same grounds. Objection sustained. Defendant excepted.
A. When I went back in the room I saw a pistol under the stove and went and picked it up.
THE COURT: The witness went ahead and answered it anyway, and I want the bill to show that.
MR. HODGES: I would rather you would stand on the ruling.
THE COURT: I would stand on the ruling if the witness had not answered it.
MR. HODGES: Well, strike it out.
THE COURT: It is too late to strike it out now after it is in.


Testimony of Charley Collins, witness for defendant (direct examination).

Q. How was she dressed the third time?
A. She was dressed the third time in the same coat, buttoned up at the top and unbuttoned the balance of the way.
Q. When she came down what did she do, when she came the last time?
A. She came down there the last time with her right hand under the coat, holding it over with the left.
Q. Unbuttoned, except the top button?
A. Yes, sir.
Q. Could you see anything?
A. Well, as the wind was blowing the coat up I could see something.
Q. What was it?
A. I could not say what it was.
Q. Was she or not mad?
A. She was mad, yes, sir, and talking angry.
The state objected to the statement as to her being angry.
THE COURT: It don't show any connection between her and the defendant.
MR. HODGES: We say that this woman was in the habit of making trouble and in the habit of carrying a pistol and drawing them on me.
THE COURST: I will sustain the objection to it and you can take your bill. I don't care to hear any argument on it after I have ruled, but if you have got any authorities I will hear them.
(Here the jury was withdrawn for the purpose of taking the testimony of witness on bill of exceptions).

EXAMINED BY MR. HODGES:
Q. Now, state what was said to you.
A. Well, when she came down the first time I told her to come down there and count the bundles, and she complained when I began throwing out the top, which was rotten, and she said I must not throw off any at all that I must take it all; I said that I would not take it; she said if I did not take it all I could not take any of it, and I told her I would wait till her son came.
Q. Had you bought it from her son?
A. Yes, sir.
Q. By the 100 bundles?
A. Yes, sir, by the dozen.
Q. Was there any agreement about throwing off the rotten ones?
A. Yes, sir.
Q. You then told her you would wait till her son came?
A. Yes, sir.
Q. Now, state what was done after that.
A. Then we waited for an hour or more and her son still did not come, and I bought the stack for $10.
Q. You then just told her you would take it all for $10?
A. Yes, sir.
Q. Then what did you do?
A. Then we went down and commenced to load and she came down afterwards; I had told her I would take the stack for $10, and I says "I will throw you off all the rotten hay, I don't want it;" and I went down and commenced to load, and she came down afterwards and she was mad and said I must take it all; well, I says, "I won't do it," and she says "Well, you will have to wait till Frank comes," and he did not come, and afterwards she came around again and said that I had agreed to throw her out twenty bundles of good hay.
Q. Did you agree to do that?
A. No, sir, I did not.
Q. Well, what did you tell her?
A. I told her I would not.
Q. Was that the time she had her hand in her bosom?
A. That was about the second time, no, sir.
Q. That was the second time?
A. Yes, sir, and she came the third time.
Q. And when she came the third time is the time you have described with her hand in under here?
A. Yes, sir.
Q. What did she do then?
A. She said I must throw her out that 20 bundles and I told her I would not do it.
Q. Did she talk pretty loud and angry?
A. Yes, sir.
Q. Did you throw them out?
A. No, sir, I would not do it.
Q. Could you see any part of what she had in her hand?
A. I could see something; it was under the coat, like that, holding it with her hand, and if any of you recollect on Saturday morning the wind blew high, and as the wind blew her coat up I saw something.
Q. What was it?
A. It looked like the end of a gun, still it might have been the end of a knife.
Q. Could you see the middle of it?
A. I could see something that looked bright.
Q. You could not swear whether it was a knife or a pistol?
A. No, sir, I could not swear what it was.
MR. HODGES: That is our bill.
THE COURT: I will give you a bill for that. You can put in your bill anything you want to as far as I am concerned, I don't care to hear it.
MR. HODGES: We ask this testimony for the reason that it is a disputed question about what demonstrations were made at the time of the homicide and we insist that this testimony is admissible as tending to explain the character of the deceased, and the probable truth as to what occurred at the time of the homicide.
THE COURT: I will exclude the testimony because it is irrelevant and immaterial, and does not tend to prove any matter material to the issue herein.

CROSS EXAMINATION BY MR. DAVIS:
Q. Well, who else was down there?
A. At that time?
Q. Yes, sir.
A. My brother was there.
Q. Where is your brother?
A. He is here.
Q. Was there anybody else besides your brother?
A. No, sir.
Q. At that time?
A. No, sir.
Q. Did you see anybody off plowing in the field?
A. Yes, sir, there were parties plowing in the field, in sight.
Q. What parties?
A. There was one man plowing - a boy.
Q. This little fellow Clem, wasn't it?
A. I don't know anything about him.
Q. Do you know him?
A. Yes, sir.
Q. Well, there was somebody off plowing, do you know who it was?
A. No; there was a man plowing north of the house.
Q. On the place, wasn't he?
A. Yes, sir.
Q. Do you know what man it was?
A. I don't know anything about who it was.

RE-DIRECT EXAMINATION:
Q. Was Frank King there during the time you were getting the hay?
A. He was there right at the last.

Same witness, on re-cross examination by the State:
Q. Who did you hear discussing her general reputation, as to whether she was a dangerous woman or not?
A. Well, there were several.
Q. Let us have them.
A. The men that she drew her guns on said she was dangerous.
Q. Who said she was dangerous?
A. Them men, that she drawed her gun on.
Q. What men were they?
A. John Hurlinger.
Q. Where does he live?
A. Right here three miles from town.
Q. Who else now?
A. Mr. Moore.
Q. Where does he live?
A. He lived last year about five miles east.
Q. He still survives, don't he?
A. Yes, sir.
Q. And Hurlinger survives?
A. Yes, sir.
Q. Where does Moore live?
A. About five miles east.
Q. He still lives?
A. Yes, sir.
Q. All of them still live?
A. Yes, sir, all of them still live.


Testimony of Wm. Hearn, for defendant:

(Direct examination)
Q. I will ask you if you know of your own knowledge whether or not her husband left home -
The State objected to any such question being asked.
Objection sustained. Defendant excepted.
Defendant then asked that the jury be retired in order to make a statement of what they expect to prove on this bill, but the State waived the withdrawing of the jury.
MR. HODGES: I will state what we expect to prove, and we ask it as a legal proposition: Our defense is that in a fit of rage, or of some character of resentment, that the deceased attempted to kill the defendant, and now we propose to show by this witness, not that the woman was generally a bad woman, but that he knows from an absolute knowledge of her that when she got mad she was violently and desperately so, and that he knows that fact, and that he saw her in a fit of passion and saw her make an assault upon a doctor and make him leave the place; that her temper was so uncontrollable that when she would get mad with her husband she would drive him from his home, and that this man went in person to settle the trouble, showing by this testimony the character of the woman as he knows it, that is, that she was a woman of violent temper; this does not go to character, but we make the legal proposition that you may show by a witness that he knows of the disposition of the party actually, and show what is known of an individual in a case of this character.
Q. Do you know, from an acquaintance with Mrs. Whiteside what her disposition was, as to being peaceable or being violent, easy to anger, quick to get mad, or quick to resent and insult, - do you know it?
Objected to. Sustained. Defendant excepted.
THE COURT: In order to get it in the bill, I desire it to show that the evidence of this witness be placed in the bill as to whether or not he knows.
Q. Do you know?
A. No, sir, I don't know; I never had no business with her. I was present at one time, as I stated to counsel.


Testimony of C. D. Whiteside, for defendant. The jury was withdrawn and the following testimony taken, as showing what the defendant expects to prove by the witness, to insert in bill of exceptions:

EXAMINED BY MR HODGES:
Q. Mr. Whiteside, you knew the disposition of Mrs. Whiteside well, did you not?
A. Of course I knew her disposition, a good deal of it, but whether it was well or not I can't say.
Q. Well, state to the court what her actions would be when she could become angry, just explain in your own way.
A. If she had been insulted, or wronged in any way?
Q. Yes, sir, when she was insulted or mad, how would she do?
A. She would take her part.
Q. Readily?
A. Yes, sir.
Q. Was she quick to anger or not - high tempered, I mean?
A. She was high tempered to resent. She was high tempered, but she did not let it run over but what she could control herself, unless she would become very mad.
Q. Now, when she would become very mad, what was her disposition?
A. When she would become very mad she would resent any wrong.
Q. Would she or not, when she became very angry, strike any person that made her angry?
A. Yes, sir, she would strike you if you had done her an injury; she was as pleasant a woman as I ever saw if there was no injury or insult, but if you done an insult or injury to her, or in trading would take advantage of her, she would resent it.
Q. She would strike with whatever she had, and strike quick?
A. Yes, sir.
Q. Now, what was her appearance when she would get mad, or was in one of those mad spells?
A. It seemed to be a mono-maniacal appearance.
Q. Describe her appearance when she would become mad, with reference to her veins, or the veins turning red, or anything?
A. Well, she would turn flush in the face and her neck veins would begin to swell up, then you might get away from her.
Q. That seemed to be her natural disposition when she was mad? You say she would strike with whatever she could when she got mad?
A. Yes, sir, she never fought me, only -
Q. I don't care about inquiring into those things.
A. In Arkansas her and a woman had a fight there; she never had a fight since that I know of.
Q. Did she or not threaten to shoot you, and you left on account of it?
A. No, sir, I did not leave on account of it; she threatened to shoot me, but her pistol was in the trunk and she never got it.
Q. You went away before the pistol was ever gotten out?
A. She never got that pistol out.
Q. You caught hold of her, didn't you?
A. She caught hold of me and I pushed her off with my hand, and I never went away from there till after that; the boys seen we were fighting, not fighting, but just pushing around the chairs in a rage, and the boys went after some of Mr. Spencer's hands, and some of those boys came over there, and they asked me to come over there till it quieted down, or I would not have gone over there.
Q. You went to Spencer's and stayed all night?
A. Yes, sir.
Q. How long did you stay away?
A. I came back next morning.
Q. Did you at any time go to Mr. Hearn's to get him to see if he could settle the trouble?
A. I asked him to go over there and talk to her, but I don't know what he said to her.

CROSS EXAMINATION:
Q. She ought to have whipped that woman in Arkansas, oughtn't she?
A. I guess so; I think she was justified in doing that.

RE-DIRECT EXAMINATION:
Q. Did the Arkansas court conclude she ought to have whipped the woman?
A. The Arkansas court fined her $5 for whipping a woman out in the public road, for fighting in the public road.

RE-CROSS EXAMINATION:
Q. But the woman had been talking about her and she ought to have whipped her?
A. Yes, sir, I don't suppose the court would have fined her if it had been any other place than the public road.

RE-DIRECT EXAMINATION:
Q. Ought she to have threatened to shoot you with that pistol? You say she ought to have whipped the Arkansas woman; ought she to have threatened to shoot you that time you left, when you had the tussle with her?
A. I think I told you that a little bit ago.
Q. I say ought she to have threatened you that way?
A. No, sir.
Q. She was wrong in that, was she?
A. Yes, sir.

RE-CROSS EXAMINATION:
Q. Mrs. Whiteside was a very industrious woman, wasn't she?
A. Yes, sir, as industrious as anybody.
Q. An honest woman, wasn't she?
A. Yes, sir.
Q. And as kind to your children as she was to her own?
A. Yes, sir, and as kind to me as anybody when she was not in a temper.
Q. And a just woman?
A. Yes, sir.
Q. But would get mad when she thought was imposing on her.
A. Yes, sir.
Q. And during the whole time you never saw her with a pistol?
A. No sir.


Testimony of A. A. Spangler, cross examination:

Witness was asked by counsel for the prosecution if he did not at a certain time and place make an assault on Martin Whiteside with a gun, or draw a gun on him to make him stop gathering corn, to which counsel for the defense objected, and the court overruled the objection and required the witness to answer, to which defendant excepted.

Same witness, cross examination:
Q. How long had Mrs. Whiteside owned these cattle?
A. About three years, as near as I can tell you, somewhere in that neighborhood.
Q. Hadn't they been levied on once as your property?
A. Yes, sir.
Q. Wasn't there a lawsuit over them?
A. Yes, sir.
Q. Didn't you swear they were her cattle?
A. I did.
MR. HODGES: We object to this testimony on this ground: That they can prove no more by this witness on the cross examination than they could prove by any other witness, and the rule is the same. That is one objection. We object upon the further ground that the matter about which they interrogated the witness had no connection whatever with the alleged crime; it is an effort to prove a different transaction, a financial transaction, rather than a personal difficulty, and it is an entirely independent matter and has no connection with anything brought out by the direct examination. The statutory provision authorizing the defendant to become a witness in his own behalf does not authorize the prosecution on cross examination to make him a witness against himself; they must confine themselves to the matters brought out on direct examination, and whenever they broach any matter not brought out by the direct examination, or not germane to that, then they make him their own witness, under the rules laid down.
THE COURT: Didn't your co-counsel prove by him that he had a half interest in these cattle?
MR. HODGES: Yes, sir.
THE COURT: Now, then, he is like any other witness, and can't they seek to show that he made contradictory statements in that matter, and that it is untrue?
Object overruled. Defendant excepted.

Same witness, cross examination:
Q. What did you put in a horse for?
A. Well, that went in on the indebtedness.
Q. Went in on the same indebtedness?
A. Yes, sir.
Q. Well, if it was all necessary to pay the indebtedness, how did you have a half interest?
A. Well, when all of that was turned in, then she owed me.
Q. What did you turn in more than was necessary for?
A. Well, it was just to keep other fellows that had robbed me off of it.
Q. It was to keep other fellows off of it that had robbed you?
A. Yes, sir.
Objected to, as being an irrelevant and collateral matter entirely.
Objection overruled. Defendant excepted.
MR. TEMPLETON: I ask the court to exclude that answer of the witness, because it was made, or was drawn out by the other side, not in response to any question of ours, and I ask the court to exclude it as irrelevant and immaterial and having no connection with this case. Now, we object, in addition to that, to any further testimony along the same line, because it is collateral, irrelevant and immaterial.
Objection overruled. Defendant excepted.
Q. Now, who had robbed you.
A. Well, there were several attachment suits filed here against me.
Q. On just debts?
A. Well, I suppose so.
Q. Is that robbery?
A. Well, it comes pretty near it; they got about $20,000 worth of stuff for about $5,000 or $6,000. Defendant excepted to all this testimony.


W. H. Douglass, witness for defendant, cross examination:

Q. Did you know that he (Spangler) had been going around here for years and years with a great big pistol in his pocket?
A. No, sir.
Q. Is that the way a peaceable man does?
Objected to. Overruled. Defendant excepted.
Q. Has he had the reputation of being a pistol toter?
Objected to, on the ground that it is a question of general reputation, and this does not affect that question.
Objection overruled. Defendant excepted.
Q. Don't you know that he has had the reputation of be a pistol toter?
A. I do not.
Q. This has been a peaceable country here, hasn't it?
Object to. Overruled. Defendant excepted.
Q. This has been a peaceable country?
A. Yes, sir. I think so.


J. B. Young, witness for defendant, cross examination:

Q. Have you heard of his being indicted or not?
Objected to. Overruled. Defendant excepted.
Q. Have you heard of his being indicted or not? (referring to defendant)
Object to, as hearsay. Overruled. Defendant excepted.
Q. Have you heard of him being indicted?
A. Yes, sir.
Q. You have heard of it in the last few years?
A. Well, I have only heard of it right recently, but it has been in the last two or three years.


J. L. Huggins, witness for defendant, re-cross examination:

Q. Do you know this man Hedley Skidmore who testified as a witness?
A. Yes, sir.
Q. Did he ever come back to your house after he had gone to Mrs. Whitesides' after the killing?
Objected to, as immaterial. Overruled. Defendant excepted.
A. I don't remember of him coming back there till after the funeral.


Charles Spangler, a witness for the State in rebuttal, direct examination:

Q. (Showing witness affidavit signed by him). Is that your signature?
A. Yes, sir.
Q. You swore to that before Mr. Milton?
A. Yes, sir.
Q. "Coming to town my father told me -"
Objected to, because the witness has answered the question, and on the further ground that it is hearsay, and an ex parte statement not made in the presence of the defendant, and defendant knows nothing about it, and because it is a matter that occurred before the grand jury, and is not admissible for the purpose of impeachment, and it is irrelevant and immaterial.
MR. DAVIS: We can impeach the witness in any way we please, except by proving his general bad character.
THE COURT: The can impeach him, or refresh his memory.
MR. HODGES: Does the State say that this witness is not credible, and that they want to impeach him? If they say they challenge the credibility of this witness I want them to state it. Do you state to the court that you challenge the credibility of this witness and want to impeach him?
MR. DAVIS: I am examining the witness about a statement he made before.
MR. HODGES: If they challenge this witness, he is their own witness and they can only impeach him in some of the ways laid down, except as to general bad character. Now, they must inform the court before they do this that that is their purpose.
THE COURT: I will admit the testimony unless you give me some reason for not admitting it.
MR. HODGES: We can give this reason: This is their witness; he has answered every question promptly, and he is not an unwilling witness, and they can read no paper to him, for any purpose.
THE COURT: Can't they read it for the purpose of refreshing his memory.
MR. HODGES: They cannot read it to refresh his memory, because he has answered every question promptly; he may take it to refresh his memory but I do say they cannot read it before the jury to refresh his memory. I state here and now that that is not the purpose of this, in my judgment that they don't want to impeach the witness, and I want them to say so in the presence of this jury.
MR. TEMPLETON: There is one other objection I want to urge. I think there is a further modification, and that is that the party must show that he has been misled by the witness, and that he has stated facts injurious to him that he did not know he would state before he put him on the witness stand.
THE COURT: Why can't he read him what he has heretofore stated - if the witness has made testimony, or made declarations, heretofore, and either if he made them outside, or if they had been reduced to writing on the outside? Why can't counsel read him what he has heretofore stated and ask him if he has not stated that heretofore?
JUDGE HURT: Can you honor put your finger on a fact sworn to by him that is injurious to the State, and unless that is so he cannot impeach him? A failure of proving a fact won't authorize it, but the testimony must be injurious to the party introducing the witness.
MR. DAVIS: If he testifies different to what he has heretofore testified, or to what we expected him to testify, it is that far injurious (unreadable).
MR. TEMPLETON: I want to make another point, (reading statute on the subject). The defendant objects further on the ground that the State has not stated that they are surprised at his testimony; defendant does not object to his showing witness the paper; let him do that, or let him read it to him, but we do object to his taking a star chamber proceeding, where we had no right to appear, and where this defendant was not present, and reading that ex parte statement, taken in that manner, as testimony before this jury.
MR. DAVIS: I just simply asked him in reference to a statement that he admitted he swore to. How can I ask him the question unless I am allowed to read it to him.
MR. HODGES: I want the record to show that counsel for the prosecution offered to read a paper signed by the witness, for the purpose of impeaching him, after they had put him on the stand and he had answered each question propounded, without any reluctance; that they offered a paper that purported to be signed by the witness, and we object to the reading of that paper for any purpose, or for the purpose of impeaching the witness, on the ground that they are not surprised, and could not be, at his testimony, which has been favorable to the prosecution on every question; and they don't show that they have been misled by him. Objections overruled. Defendant excepted.

Charles Spangler, re-called by defendant in rebuttal, direct examination:
Q. Did you ever hear Mrs. Whiteside, in the presence of Frank King, her son, swear or curse?
A. Yes, sir.
Q. When was it?
Objected to, as immaterial and irrelevant, and that a witness cannot be contradicted on an immaterial matter.
The testimony is offered for the purpose of contradicting Frank King.
Objection sustained. Defendant excepted.
At the request of the defendant the jury was withdrawn, in order to get the testimony of witness for the purpose of bill of exceptions.
MR. HODGES: Witness Frank King testified on direct examination that on Sunday, the day before the killing, he was present and heard the conversation between defendant and deceased, and the deceased did not swear on that occasion; on cross-examination he re-affirmed this statement and said that he never heard deceased swear at any time in his life, that if she ever swore she never swore in his presence, that he had any recollection of. We drew that out on the cross examination. Defendant now offers Charley Spangler and proposes to prove by him the following facts, also for the purpose of showing that the deceased was in the habit of cursing and swearing and using profane and vulgar language when angry. To which the state objected, and the objection was sustained, and defendant excepts.
Q. Now, Charley, state what she said and how she came to say it?
A. Well, Frank and I had had a little racket, and the next day I met her in the road, and she just stopped her wagon and commenced cursing me for all sorts of sons of bitches and bastards and liars, and all such as that.
Q. When and where was that?
A. Over there in the road, the other side of the Sisson place.
Q. When was that?
A. Three years ago, I think.
Q. Was she or not angry?
A. I think she was.
Q. Was Frank King, her son, present at the time, and did he hear it?
A. Yes, sir, he was in the wagon with her.
Q. Now, was she or not in the habit of cursing and swearing?
A. Yes, sir.
Q. Was she or not in the habit of using profane and vulgar language?
A. Yes, sir, I have heard her several times.
Q. Did you ever hear her use such language at any other time in Frank's presence, than the one you have mentioned?
A. Yes, sir, once right there in the lot.
Q. Now, when was that?
A. That was about three years ago, about two weeks before this racket that me and Frank had.
Q. What was she cursing about then?
A. She was cursing the folks at home.
Q. What folks?
A. My mother and sister.
Q. Now, was Frank present at that time?
A. Yes, sir, he was standing right close to her.

Cross examination:
Q. Did you ever hear your father curse and swear?
Objected to. Sustained.
MR. DAVIS: We object to all this testimony as immaterial and irrelevant, and we object to it upon the further ground that the defendants had closed their case, and this is not in rebuttal of anything we introduced.
Object sustained, but the court stated that it was not sustained upon the ground that the testimony was not in rebuttal.


A. A. Spangler, re-called for defendant in rebuttal, direct examination:

Q. What did you state over at the jail?
A. I told Mr. Fuller that I expected he would find that pistol on the floor.
Q. You knew where her body was?
A. Yes, sir, I did.
Q. You did not expect when you went down to the barn and told Smith about it, that when Smith got back to the house he would find the woman had got up and gone back in the kitchen and laid down on the floor?
A. No, Sir.
Q. Did you expect him to find the pistol on the floor?
A. Yes, sir, I expected it.
Object to. Sustained. Defendant excepted.