Justia Constitutional Law Opinion Summaries

Just after 2 A.M., officers were dispatched to a fast food restaurant following a complaint of a disturbance between the restaurant’s customers and two intoxicated men. Upon arrival, the officer encountered two men that matched the complainant’s description; the men were sitting in a truck with the engine running in the restaurant’s parking lot. The officer told appellee three times to turn off the truck before appellee complied. Appellee had answered the officer's initial requests to turn off the truck with claims that he was not driving and that he was moving the truck for someone else. The officer had appellee exit the truck, at which time he also smelled alcohol on appellee's breath and saw that his eyes were bloodshot. To investigate his suspicion that appellee may have been driving while intoxicated, he placed appellee unhandcuffed into the back of his patrol car and called for a department DWI specialist. Appellee failed field sobriety tests and was arrested for DWI. The trial court granted appellee’s motion to suppress appellee's oral statements made to the officers. In response to the State's request, the trial court made findings of fact and conclusions of law: that the responding officer had no reasonable suspicion to detain appellee for the disturbance in the restaurant and that appellee was "under arrest for suspicion of DWI when [the DWI specialist] began questioning" him without giving him the statutory warnings. On the State's petition for discretionary review, the Supreme Court determined that the court of appeals erred: (1) by failing to apply a de novo standard of review to the trial court's ultimate legal determination that appellee was in custody when he made incriminating statements to police; and (2) by failing to abate the appeal for further findings of fact by the trial court. The case was reversed and remanded to the court of appeals with instructions to abate the case to the trial judge for supplemental findings. View "Saenz v. Texas" on Justia Law

Appellant Jamie Zamora and his brother Danny had a business selling cocaine and marijuana. His brother ran the business in Mexico, and appellant was in charge of distribution throughout the Houston area. Appellant received the assistance of salesmen in Houston who helped him distribute the drugs. The issue before the Supreme Court in this case centered on whether a trial court must, sua sponte, give an accomplice-witness instruction when the evidence raises the issue under the theory that the witness was a party as a co-conspirator. The Supreme Court answered that question affirmatively. Furthermore, the Court held that when the issue of a trial court's failure to give an accomplice-witness instruction is raised on appeal, a court of appeals should first determine whether a trial court erred by failing to sua sponte give that instruction before it considers whether a defendant preserved his complaint for appeal, a matter that is pertinent to a harm analysis. Because it failed to address the question of charge error in the first instance, the Court held that the appellate court erred by determining that appellant forfeited his jury-charge complaint by failing to request an accomplice-witness instruction that was based specifically on a co-conspirator theory of party liability. This case was remanded to the court of appeals for further proceedings. View "Zamora v. Texas" on Justia Law

Ben Chambless appealed the court of appeals' judgment affirming his sentence of eight years' confinement for committing criminally negligent homicide. Upon careful consideration of the record of this case, the Supreme Court affirmed the court of appeals' conclusion that the jury instructions properly defined the punishment range of a third-degree felony because there was no conflict between the relevant statutes, the state-jail felony deadly-weapon punishment enhancement was applicable to criminally negligent homicide, and its application was not contrary to legislative intent. View "Chambless v. Texas" on Justia Law

A jury convicted appellant Samantha Britain of manslaughter and injury to a child for recklessly causing the death of her step-daughter. The Court of Appeals held that there was insufficient evidence that appellant was "aware of but consciously disregard[ed] a substantial and unjustifiable risk" as required to prove recklessness. Accordingly, the court reversed the trial court and entered a judgment of acquittal on both counts. The Supreme Court granted the State's petition for review of whether the Court of Appeals should have reformed the verdict to the lesser-included offense of criminally negligent homicide rather than rendering a verdict of acquittal. The Supreme Court concluded there was no evidence concerning the standard of care an ordinary person should be held to or that showed the appellant should have been aware of the risk to the child. Given this lack of evidence and the conflicting testimony of the medical experts concerning the ease with which such a serious risk was identified, the Court could not say that the State proved beyond a reasonable doubt that the appellant acted with negligence. The Court of Appeals did not err in rendering a judgment of acquittal, and the Supreme Court affirmed that decision. View "Britain v. Texas" on Justia Law

Appellant Ronald Glen Boston was found guilty of aggravated robbery and was sentenced to fifty-five years' imprisonment, conviction and sentence affirmed on appeal. The Supreme Court granted review to determine whether the Court of Appeals erred when it held that the victim was threatened or placed in fear of imminent bodily injury or death when the evidence showed that no threat was perceived by the victim. Because the Supreme Court concluded that a rational jury could have inferred that the victim was threatened and placed in fear, it affirmed the appellate court's judgment. View "Boston v. Texas" on Justia Law

Appellant was convicted of unlawful possession by a felon of a firearm and possession of body armor. The trial judge entered a deadly-weapon finding in the body-armor case. The issue before the Supreme Court on appeal of this case was one of first impression: whether, for purposes of Article 42.12, 3g, must the "exhibition" of a deadly weapon facilitate, in some manner, the associated felony offense, or was it sufficient that the exhibition of the deadly weapon occurs simultaneously with the felony but is unrelated to its commission? After careful consideration, the Supreme Court concluded that there must be some facilitation purpose between the weapon and the associated offense to support a deadly-weapon finding. Because there was no evidence that appellant's possession of a mini-Glock pistol facilitated his commission of the offense of possession of body armor, the Court deleted the deadly weapon finding from the judgment. View "Plummer v. Texas" on Justia Law

Appellant Kody William Farmer was convicted of driving while intoxicated and sentenced to 90 days' confinement and to pay a $200 fine. The question on appeal to the Supreme Court in this case centered on whether there was sufficient evidence introduced at trial to entitle Appellant to a jury-charge instruction on voluntariness. The court of appeals held that Appellant was entitled to a voluntariness instruction. Appellant suffered from chronic back pain due to a work-related injury. As a result, he had taken different medications on and off for more than 10 years, including Ultram, (a painkiller), and Soma (a muscle relaxer). Four days prior to the incidents at issue here, Appellant was prescribed Ambien (a sleep aid), for the first time to assist with insomnia. On the night he was pulled over, appellant stated to police that he did not remember taking any of his medications. At trial, Appellant's wife testified that she did not remember seeing Appellant take his medication that morning, but she remembered that "the Ambien I laid out for the night that was on the other side of [the] microwave was gone." She also testified that she was a hundred percent certain that "he took what I had laid out." Appellant appealed his conviction, and the court reversed Appellant's conviction and remanded to the trial court. It held that the facts of this case were "most closely akin to an involuntary act because the evidence suggests that although Farmer voluntarily took the pills laid out for him by his wife, he involuntarily took the Ambien pill because of his wife's act." Upon review, the Supreme Court concluded that Appellant's action in taking the Ambien pill was a voluntary act because Appellant, of his own volition, picked up and ingested the Ambien pill. Because no other evidence at trial raised an issue of Appellant's voluntariness in taking that medication, the trial court properly denied Appellant's request. As a result, the court of appeals erred when it reversed the judgment of the trial court. View "Farmer v. Texas" on Justia Law

In his initial application for habeas relief, applicant Erick Alberto Oranday-Garcia alleged his guilty for possession of cocaine was involuntary because trial counsel rendered deficient performance by advising him that conviction for that offense would not result in deportation. Applicant was deported as a result of his offense. He contended that had he understood the effect that the guilty plea would have on his immigration status, he would not have pled guilty but insisted on going to trial. Applicant's trial counsel filed an affidavit with the convicting court specifically refuting the applicant's allegations and maintaining that he had informed the applicant that his conviction would result in deportation. Based on the affidavit, the convicting court recommended denying relief. In a subsequent writ application, applicant argued that the same circumstances in support of his claim that his plea was given involuntarily due to ineffective assistance of trial counsel was supported under the United States Supreme Court's decision in "Padilla v. Kentucky." Applying the requirement of an allegation of prima facie facts to this petition, the Supreme Court dismissed it as non-compliant with Article 11.07, Section 4. The new law that applicant invoked was Padilla, but the Court concluded he did not establish that Padilla applied to the facts of his case because of Texas precedent "Ex parte De Los Reyes," and the United States Supreme Court's opinion in "Chaidez v. United States." Because the applicant's conviction was final before the Supreme Court announced the rule in Padilla, it could not apply to him in any event. View "Ex parte Oranday-Garcia" on Justia Law

The trial court found appellant was indigent and appointed trial counsel for him. Subsequently, the court accepted appellant's guilty plea for hindering apprehension and sentenced him to eight years' confinement in the penitentiary. Thereafter, the trial court suspended the appellant's sentence and imposed eight years' community supervision. Without making a finding that the appellant had the present resources to repay the county for his court appointed trial attorney, the trial court ordered the appellant to pay court costs, which, according to a bill of costs attached to the written judgment, included attorney fees. Appellant did not appeal at the time of the imposition of community supervision. But when the appellant's community supervision was later revoked and he was sentenced to eight years' incarceration, that's when appellant raised the issue of the sufficiency of the evidence to support the trial court's order to repay attorney fees. The court of appeals acknowledged that the evidence was insufficient to order the repayment of those initial attorney fees, but held that the appellant procedurally defaulted this claim by failing to raise an objection in the trial court at the time that community supervision was imposed. After careful consideration, the Supreme Court concluded appellant procedurally defaulted his claim. View "Wiley v. Texas" on Justia Law

Appellant was convicted of second-degree felony possession of marijuana. She initially preserved error by way of a motion to suppress the evidence, which she claimed had been seized during the course of an illegally prolonged roadside detention. But when the evidence was later proffered by the State during the punishment portion of the unitary proceeding following her non-negotiated plea of guilty to the charge, her attorney expressly declared that he had "no objection" to the admission of the evidence. The trial court nevertheless manifested its understanding that the appellant persisted in her wish to appeal the denial of her pretrial motion to suppress and expressly granted her permission to do so. The court of appeals refused to reach the merits of her claim, relying upon longstanding precedent that her attorney had "waived" the previously preserved objection to the evidence for purposes of appeal when he declared that he had "no objection" to its admission. Given the record as a whole, the Supreme Court concluded court of appeals erred by stating that when appellant stated she had "no objection" to the introduction of certain evidence during the punishment portion of the proceedings in this case, she "waived" appellate review of the propriety of the trial court's ruling on her pretrial motion to suppress. Accordingly, the Court reversed the court of appeals and remanded the case for further proceedings. View "Thomas v. Texas" on Justia Law