On June 1, 2026, a South Carolina jury found Columbia convenience-store owner Rick Chow not guilty of murder in the 2023 shooting death of 14-year-old Cyrus Carmack-Belton. According to reporting, Chow suspected the teen of stealing water bottles, a confrontation followed, and the defense argued Chow fired in self-defense after the teen allegedly pointed a gun; prosecutors argued the shooting was not justified. The verdict, reached after roughly eight hours of deliberation, has sparked protests and a renewed national debate over self-defense, deadly force, and property crime (The State).
The Chow case was tried in South Carolina under that state's law. But the questions it raises—when can you use deadly force, and does protecting property ever justify it?—come up constantly in Texas. As criminal defense attorneys in Frisco and across the DFW metroplex, we want to explain how a case with these facts would be analyzed under Texas law, because the Texas rules are widely misunderstood.
Texas Self-Defense: The Basic Rule
Under Texas Penal Code § 9.31, a person is justified in using force against another when and to the degree they reasonably believe the force is immediately necessary to protect against another's use or attempted use of unlawful force. Section 9.32 goes further: deadly force is justified only when the person reasonably believes it is immediately necessary to protect against another's use or attempted use of unlawful deadly force, or to prevent the imminent commission of certain violent felonies such as aggravated kidnapping, murder, sexual assault, aggravated sexual assault, robbery, or aggravated robbery.
Two words do the heavy lifting: reasonable and immediate. The belief must be objectively reasonable, and the threat must be imminent—happening now, not a threat that has already passed.
Texas Has No Duty to Retreat—With Conditions
Texas is a “stand your ground” state. Under § 9.32(c)–(d), a person who has a right to be present, did not provoke the other person, and is not engaged in criminal activity has no duty to retreat before using force, and a jury may not even consider whether the person failed to retreat. That is a meaningful protection—but notice the conditions: you must not be the provoker and not be committing a crime yourself. Chasing someone can undercut a self-defense claim, because the law protects defense against an imminent threat, not pursuit after a threat has ended.
The Crucial Point: Deadly Force to Protect Property Is Sharply Limited
This is where public assumptions most often go wrong. Many people believe Texas lets you shoot someone for stealing. The reality is far narrower.
- § 9.41 allows a person to use force (not deadly force) to protect their own property from trespass or unlawful interference.
- § 9.42 permits deadly force to protect property only in tightly defined situations—to prevent imminent arson, burglary, robbery, aggravated robbery, theft during the nighttime, or criminal mischief during the nighttime, and only when the person reasonably believes the property cannot be protected by other means or that using lesser force would expose them to substantial risk of death or serious bodily injury.
Petty shoplifting of low-value items in broad daylight does not, on its own, authorize deadly force in Texas. A jury would scrutinize whether the shooter reasonably believed deadly force was immediately necessary, whether the alleged victim actually posed a deadly threat, and whether the shooter provoked or prolonged the encounter.
How a Texas Jury Would Frame the Question
If a case with these facts were tried in Collin, Denton, Dallas, or Tarrant County, the central battleground would be the same one that played out in South Carolina: did the defendant reasonably believe deadly force was immediately necessary to protect against deadly force, or was this an unjustified response to a fleeing suspect? The defense would emphasize the alleged weapon and the danger to a family member; the prosecution would emphasize pursuit, the disparity between a property crime and a fatal shooting, and whether the threat was truly imminent. In Texas, the State must disprove a properly raised self-defense claim beyond a reasonable doubt—a high bar that is often decisive.
Frequently Asked Questions
Can I use deadly force to stop someone stealing from my store in Texas?
Generally no, not for ordinary shoplifting. Deadly force to protect property is limited by § 9.42 to specific serious crimes and circumstances, and even then only when no other reasonable means exist. Most theft does not qualify.
Does Texas's “stand your ground” law mean I can shoot anyone I feel threatened by?
No. Stand your ground removes the duty to retreat, but you still must reasonably believe deadly force is immediately necessary against an imminent deadly threat, and you must not be the provoker or engaged in crime yourself.
Does chasing someone hurt a self-defense claim?
It can. Self-defense protects against imminent threats. Pursuing a fleeing person can suggest the threat had passed, which a prosecutor will use to argue the force was not immediately necessary.
Who has the burden of proof on self-defense in Texas?
Once a defendant produces some evidence raising self-defense, the State must disprove it beyond a reasonable doubt. The defendant does not have to prove innocence.
How L&L Law Group Can Help
At L & L Law Group, PLLC, we defend people charged with violent offenses, including homicide and aggravated assault, throughout Frisco and the DFW area. Self-defense and defense-of-property cases turn on fine distinctions—reasonableness, imminence, provocation, and the precise statute that applies—and on holding the State to its burden of disproving justification beyond a reasonable doubt. If you or a loved one is facing charges arising from a shooting, altercation, or use-of-force incident, contact us for a confidential consultation.