There lies the question , who would want to frame him enough to kill someone ? That is a flaw in your analysis . Why does the murder result from the desire to frame ? Couldn ' t the murder have happened and the planting come from convenience or a desire to point focus away from the culprit ? AND of course what would be SAs motive to kill TH ? Crime of passion is the only legitimate explanation . There is absolutely no evidence that Avery planned out Teresa ' s murder , and there is strong evidence to contradict any theory of premeditation . AND where ? Not in the trailer , not in the garage , no sign of a crime scene outside either . What if she was killed by method other than shooting ? Strangulation could have happened on site . There isn ' t enough evidence to point to a definitive cause of death . Maybe she was shot postmortem at the location where the Rav 4 was found . In fact , what if Avery was involved after the fact because a family member committed the crime and he helped cover it up , much like what Brendan described in his confession ?