Andrew Castillo v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 27, 2024
Docket07-23-00193-CR
StatusPublished

This text of Andrew Castillo v. the State of Texas (Andrew Castillo v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrew Castillo v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-23-00193-CR

ANDREW CASTILLO, APPELLANT

V.

THE STATE OF TEXAS, APPELLEE

On Appeal from the 364th District Court Lubbock County, Texas Trial Court No. DC-2023-CR-0108, Honorable William R. Eichman, II, Presiding

August 27, 2024 MEMORANDUM OPINION Before QUINN, C.J., and DOSS and YARBROUGH, JJ.

Following a plea of not guilty, Appellant, Andrew Castillo, was convicted by a jury

of aggravated sexual assault of a child.1 By his six issues, he contends the trial court

erred by: (1) setting a competency hearing not authorized by statute; (2) granting the

State’s late-filed motion for redetermination when it lacked jurisdiction; (3) shifting the

burden to him to prove continuing incompetency; (4) denying his motion to suppress his

1 TEX. PENAL CODE ANN. § 22.021(a)(2)(B). confession; (5) failing to exclude certain exhibits which were not relevant and prejudicial;

and (6) improperly permitting an inadmissible outcry statement. We affirm.

BACKGROUND

One evening, Appellant and the mother of his child went to sleep in their bedroom.

The mother awoke in the middle of the night to find Appellant not in the couple’s bed. She

frantically searched the home and found Appellant naked in the living room next to their

three year old daughter. Mother grabbed the child and asked her what happened, and

the child pointed to the car in the driveway and said, “Daddy touched my butt.” Appellant

was adamant nothing happened and left the house, and mother asked her ex-boyfriend

to stay the rest of the night to keep Appellant away. Upon questioning her daughter again,

the child said to her mother, “Daddy hurt my butt.” The following day, mother reported

the incident to the police.2 The daughter was examined by a sexual assault nurse

examiner who confirmed she had suffered an injury to her anus.3 After the exam, mother

brought her daughter to the Child Assessment Center of the South Plains (“CAC”) for a

forensic interview, but the interview was rescheduled to the following day due to the child

being emotional and uncooperative. The police also investigated the child’s allegation.

During the investigation, detectives discovered text messages sent by Appellant to

mother admitting he assaulted his daughter. Appellant was arrested and charged with

sexual assault of a child.

2 Mother apparently waited out of concern about her children—the daughter and her three older

brothers—being taken away by CPS. Apparently, this occurred previously with her children.

3 The nurse examiner could not determine the cause of the injury.

2 In 2018, after his arrest, Appellant was declared incompetent to stand trial and

committed to a long-term treatment facility. In 2021, the forensic psychologist acting as

the head of the facility, Dr. Mitchell, filed a report stating Appellant had regained his

competence. After a hearing and examining the Appellant, the trial court determined he

was still incompetent to stand trial and signed an order continuing the commitment. Less

than 91 days later, Dr. Mitchell filed another request for redetermination without any

additional evidence of competency, and the hearing on the motion, which began in late

2021 was continued to March 2022. During the pendency of Dr. Mitchell’s motion, the

commitment order expired. The trial court denied the motion, and a month later the State

filed another motion for redetermination of Appellant’s competency. The trial court held

another competency hearing based on the State’s motion and found Appellant competent

to stand trial. At trial, a jury found him guilty and sentenced him to life imprisonment and

a fine of $10,000. This appeal followed.

APPLICABLE LAW

“As a matter of constitutional due process, a criminal defendant who is incompetent

may not stand trial.” Bluntson v. State, No. AP-77,067, 2021 Tex. Crim. App. Unpub.

LEXIS 349, at *8 (Tex. Crim. App. June 30, 2021) (quoting Boyett v. State, 545 S.W.3d

556, 563 (Tex. Crim. App. 2018)). “Due process also mandates state procedures that are

adequate to assure that incompetent defendants are not put to trial.” Bluntson, 2021 Tex.

Crim. App. Unpub. LEXIS 349, at *8 (quoting Turner v. State, 422 S.W.3d 676, 689 (Tex.

Crim. App. 2013)). The procedures governing determination of competency of a

defendant to stand trial are embodied in chapter 46B of the Texas Code of Criminal

Procedure. TEX. CODE CRIM. PROC. ANN. arts. 46B.001–46B.171.

3 The defendant is presumed competent to stand trial unless proved to be

incompetent by a preponderance of the evidence. Art. 46B.003(b). When the defendant

is charged with a felony, if after hearing evidence a trial court determines the defendant

is not competent, the court is required to order the defendant to a restoration competency

program. Art. 46B.071(a). If, however, the trial court determines the defendant is not

only incompetent but is unlikely to be restored to competency in the foreseeable future, it

is required to hold a hearing to determine if the defendant should be committed to a

mental health facility under the Texas Health & Safety Code. Arts. 46B.071(b), 46B.102;

TEX. HEALTH & SAFETY CODE ANN. §§ 574.001–574.203.

An order of commitment to a mental health facility may be extended for a maximum

of twelve months. TEX. HEALTH & SAFETY CODE ANN. § 574.035(h). After the expiration of

the court’s order and subject to disapproval by the trial court or the State’s attorney, if the

mental health facility wishes to release the defendant, it must notify the trial court of the

release within fourteen days and whether the defendant has attained competency to

stand trial. § 574.085; TEX. CODE CRIM. PROC. ANN. art. 46B.107(a)–(c). Upon receiving

notice from the facility, or on motion of the State’s attorney or its own motion, the trial

court is required to hold a hearing to determine if the defendant should be released under

the criteria prescribed in the Health & Safety Code. TEX. CODE CRIM. PROC. ANN. art.

46B.107(d); TEX. HEALTH & SAFETY CODE ANN. § 574.035(a). The trial court must find by

clear and convincing evidence the defendant has not been restored to competence.

During the commitment, the trial court may, at any time, on its own motion or on

the motion of the facility head or State’s attorneys, hold a hearing to determine if the

defendant has been restored to competency. TEX. CODE CRIM. PROC. ANN. art. 46B.108.

4 If the facility head provides an opinion the defendant has regained competency, the

defendant bears the burden of proving by preponderance his continuing incompetency.

Art. 46B.113(d). If no opinion has been provided, it is the State’s burden to prove the

defendant’s competency by a preponderance. Art. 46B.113(e). If the trial court has

entered a determination of incompetency within 91 days of the filing of the motion, the

trial court may hold a hearing only if it “first finds reason to believe the defendant’s

condition has materially changed since the prior determination that the defendant was not

restored to competency.” Art. 46B.115(b). If the defendant is found competent, the trial

on the criminal charge may proceed. Art. 46B.116.

STANDARD OF REVIEW

A trial judge’s finding regarding competency is reviewed under an abuse of

discretion standard. Mason v. State, No. 07-14-00345-CR, 2015 Tex. App. LEXIS 12515,

at *10 (Tex.

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