By Deandra Grant & Griffin Grant
Welcome to The Defense File where we examine the criminal cases of public figures through the lens of Texas criminal law. Each entry looks at what happened in court, what the defense argued, and what a defendant would have faced (and how they might have been defended) if the same facts had occurred in Texas.
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The Incident
On the night of November 16, 1999, Rae Carruth (a wide receiver for the Carolina Panthers) drove ahead of his pregnant girlfriend, Cherica Adams, on a Charlotte, North Carolina street. A car pulled alongside Adams’ vehicle and a gunman fired four shots through her window. Adams, eight months pregnant, managed to call 911 before losing consciousness. On that call, she identified Carruth, telling the dispatcher that his car had slowed in front of hers, blocking her escape.
Adams died four weeks later. Her son, Chancellor Lee Adams, was delivered by emergency cesarean section and survived, though he was left with cerebral palsy caused by oxygen deprivation during the attack. Carruth was arrested on November 25, 1999 after being found hiding in the trunk of a car in Tennessee. The gunman, Van Brett Watkins, was captured separately.
Prosecutors argued Carruth had orchestrated the murder to avoid paying child support. He was already supporting one child and had contested paternity of Adams’ baby. The State’s theory: he paid Watkins and two other men to kill her before the child was born.
The Charges
Carruth was charged with:
- First-degree murder (premeditated)
- Conspiracy to commit murder
- Discharging a firearm into occupied property
- Using an instrument to destroy an unborn child
The first-degree murder charge required the prosecution to prove premeditation and deliberation (i.e. that Carruth planned and intended Adams’ death). The conspiracy charge required proof that Carruth entered into an agreement with Watkins and others to commit murder and that at least one overt act was taken in furtherance of that agreement.
The “destruction of an unborn child” charge arose from the injury to Chancellor. North Carolina law recognized harm to a viable fetus as a separate criminal offense, distinct from any harm to the mother.
What Happened in Court
The trial began in October 2000 and became one of the most widely covered criminal cases of that era. The prosecution’s evidence was substantial:
- Adams’ own 911 call, in which she described Carruth slowing his vehicle to trap her, played in court.
- Van Brett Watkins, the gunman, testified for the prosecution after pleading guilty. He described the planning of the attack in detail, including payments and meetings with Carruth.
- Cell phone and pager records placed Carruth in contact with Watkins and the other co-conspirators in the days and hours before the shooting.
- A fourth man, Michael Kennedy, also cooperated with prosecutors.
The defense’s strategy centered on distancing Carruth from the specific intent to kill. His attorneys argued that Carruth may have been involved with the men but had no knowledge that Watkins intended to shoot Adams. The defense portrait of Carruth was of a man who got entangled with dangerous people but did not order or intend the killing.
The jury did not fully accept the prosecution’s theory. In January 2001, Carruth was acquitted of first-degree murder. But he was convicted on the three remaining charges including conspiracy to commit murder, discharging a firearm into occupied property, and using an instrument to destroy an unborn child. He was sentenced to 18 to 24 years in prison.
Watkins received a 40-to-50-year sentence. He later expressed remorse and wrote a letter to Chancellor, whom he described as the true victim. Carruth served his sentence at Sampson Correctional Institution and was released in October 2018 after serving nearly 19 years.
Chancellor Lee Adams, now in his mid-twenties, lives with cerebral palsy and requires ongoing care. He was raised by his maternal grandmother, Saundra Adams, who has spoken publicly about his progress and her forgiveness of Carruth. Saundra Adams has been selective about contact between Chancellor and Carruth since his release.
The Texas Analysis
If this case had occurred in Texas, Rae Carruth would not have been charged with first-degree murder. He would have been charged with capital murder — a death-eligible offense.
Capital Murder for Hire: Texas Penal Code §19.03(a)(3)
Texas Penal Code §19.03(a)(3) defines capital murder to include murder committed for remuneration or the promise of remuneration, or employing another to commit murder for remuneration or the promise of remuneration. Both the person who pays and the person who receives payment can be charged with capital murder under this provision.
This is the statute that would apply to Rae Carruth. If the prosecution’s theory in North Carolina (that Carruth paid Van Brett Watkins to kill Cherica Adams) is credited, then every element of Texas capital murder is satisfied. The offense carries one of two punishments: death, or life imprisonment without the possibility of parole. There is no middle ground.
The fact that the North Carolina jury acquitted Carruth of first-degree murder is significant in terms of what it reveals about the evidence but it would not insulate him from a Texas capital murder charge. The Texas statutory structure does not require proof that Carruth was the one who pulled the trigger. Employing another to commit murder for remuneration is itself the capital offense, regardless of who fired the weapon.
Criminal Conspiracy: Texas Penal Code §15.02
Texas Penal Code §15.02 defines criminal conspiracy as an agreement between two or more persons to engage in conduct that constitutes a felony, with at least one overt act committed in furtherance of the agreement. The charge mirrors what Carruth was convicted of in North Carolina, and the elements are substantially similar.
In Texas, conspiracy to commit capital murder is itself a first-degree felony carrying 5 to 99 years or life in TDCJ. If the capital murder charge itself was pursued to trial and Carruth was convicted, the conspiracy count would likely merge into or be superseded by the capital verdict. But if the prosecution sought to hedge (as happened in North Carolina where the first-degree murder acquittal still left the conspiracy conviction intact) a Texas jury could convict on conspiracy even without finding guilt on the capital charge.
The Unborn Victims Question: Texas Penal Code §1.07(26) and §19.06
Texas law recognizes an unborn child as an “individual” for purposes of the homicide statutes. Texas Penal Code §19.06 provides that the homicide chapters apply to the death of an unborn child at any stage of gestation. Chancellor Adams survived, but the attack caused him severe permanent injury. Texas Penal Code §22.04 (injury to a child) could potentially apply given the harm caused to a child who survived the attack with permanent disability. Prosecutors would face questions about how to charge conduct that caused serious bodily injury to a person who was, at the time of the attack, an unborn child.
Case Results
How Would the Defense Approach This in Texas?
The North Carolina defense strategy (distancing Carruth from specific intent to kill) would face a significantly harder road in a Texas capital murder case. Under §19.03(a)(3), the prosecution does not need to prove that Carruth pulled the trigger. It needs to prove he employed Watkins for remuneration. The 911 call, Watkins’ testimony, and the cell phone records tying Carruth to the planning would be the same evidence the Texas prosecution would use.
A Texas defense team would focus on several pressure points:
- Watkins’ credibility. A cooperating witness who pleaded guilty in exchange for testimony is vulnerable on cross-examination. The defense would examine every inconsistency in Watkins’ account, every benefit he received for cooperating, and the circumstances under which his testimony was developed.
- The remuneration evidence. The capital murder-for-hire statute requires proof that the murder was committed for remuneration or the promise of remuneration. The defense would demand production of every financial record, bank statement, and witness account relating to any payments, and would challenge whether the evidence established an actual agreement for payment rather than a loose criminal association.
- Article 38.23 — the cell phone and pager records. Texas’s exclusionary rule applies to any evidence obtained in violation of the Texas or United States Constitutions. The defense would examine how law enforcement obtained Carruth’s communications records, whether proper legal process was followed, and whether any suppression argument was available.
- The 911 call as dying declaration. Adams’ call to 911 would be admissible under the dying declaration and excited utterance hearsay exceptions. A Texas defense team would analyze the foundation for those exceptions and examine whether any portion of the call was subject to challenge under the Confrontation Clause.
- Mental state and intent. Even under the Texas capital statute, the prosecution must prove Carruth’s specific mental state. The defense argument that he was present but unaware of Watkins’ intent to kill (the same argument the North Carolina jury partially credited on the first-degree murder count) would be developed with equal rigor in Texas.
The candid assessment: this is a case with strong government evidence: a victim’s dying declaration identifying the defendant, a cooperating co-conspirator, and corroborating phone records. In Texas, with capital murder on the table, the stakes are existential. The defense would need to aggressively challenge the cooperator’s credibility and the sufficiency of the remuneration evidence, while simultaneously building a mitigation record for the punishment phase as insurance against a guilty verdict.
What This Case Means
The Rae Carruth case is frequently cited as one of the most shocking criminal cases in NFL history, and justifiably so. But the legal lessons it offers extend beyond celebrity. The architecture of the prosecution (building a murder-for-hire case on cooperating co-defendant testimony, communications records, and a victim’s own dying account) is the same architecture used in Texas criminal courts every day.
And the Texas statute the case would invoke (capital murder for remuneration) is broader and more severe than what Carruth faced. The acquittal on first-degree murder that North Carolina’s jury returned would not have been available in the same way in Texas. Under §19.03(a)(3), employing the shooter is enough. The person who hires does not need to be present. The person who hires does not need to fire the weapon. The agreement and the remuneration are the offense.
Related Reading on Deandra Grant Law
- Murder Defense in Texas — How Texas capital and non-capital murder charges are prosecuted and defended.
- What Is a Grand Jury Defense Packet? — The pre-indictment window in murder cases and why it matters.
The Defense File is an educational series. All Texas analysis is hypothetical and does not constitute legal advice about any specific case.
If you or a family member is facing murder or serious felony charges in Texas, call (214) 225-7117 for a free, confidential consultation. Or schedule online at texasdwisite.com.
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