Anthony Hudson v. State

Court of Appeals of Texas·Decided April 7, 2010·No. 06-09-00145-CR·Published

Opinion

                                                         In The

                                                Court of Appeals

                        Sixth Appellate District of Texas at Texarkana

                                                ______________________________

                                                             No. 06-09-00145-CR

                               ANTHONY JAMES HUDSON, Appellant

                                                                V.

                                     THE STATE OF TEXAS, Appellee

                                       On Appeal from the 336th Judicial District Court

                                                             Fannin County, Texas

                                                            Trial Court No. 21068

                                          Before Morriss, C.J., Carter and Moseley, JJ.

                                            Memorandum Opinion by Justice Moseley


                                                      MEMORANDUM OPINION

            Some five years after his indictment on a charge of attempted indecency with a child, Anthony James Hudson’s case was finally set for trial.  After having filed a motion to dismiss under a claim that he had not been afforded a speedy trial and having heard that motion denied, Hudson entered a plea of guilty.  Pursuant to a plea bargain, the adjudication of Hudson’s guilt was deferred; he was placed on community supervision for five years and was ordered to pay a $2,000.00 fine.  Hudson now appeals his conviction on the sole ground that the trial court erred in denying his motion for a speedy trial.  Because we find no error in the trial court’s actions, we affirm its judgment. 

            As a defendant accused of a crime, Hudson had an interest in mitigation of the anxiety and concern that accompanied his public accusation, avoidance of impairment to his defense, and freedom from oppressive pretrial incarceration.  Cantu v. State, 253 S.W.3d 273, 280 (Tex. Crim. App. 2008) (citing Barker v. Wingo, 407 U.S. 514, 532 (1972)).  The right to a speedy trial is guaranteed by the Sixth Amendment to the United States Constitution.  Id.  This right attached once Hudson was arrested or charged.  Id.

            The right to a speedy trial defies quantification in days or months.  Barker, 407 U.S. at 523. Thus, Texas courts “analyze federal constitutional speedy-trial claims ‘on an ad hoc basis’ by weighing and then balancing the four Barker v. Wingo factors.”  Cantu, 253 S.W.3d at 280.  These factors include:  (1) the length of the delay, (2) the reasons occasioning the delay, (3) the assertion by the accused of the right to a speedy trial, and (4) the prejudice caused to the accused by the delay.  Id.; Barker, 407 U.S. at 530.  “[T]he greater the State’s bad faith or official negligence and the longer its actions delay a trial, the less a defendant must show actual prejudice or prove diligence in asserting his right to a speedy trial.”  Cantu, 253 S.W.3d at 280–81.  No one factor is determinative, and all factors must be considered together along with relevant circumstances on a case-by-case basis.  Id. at 281. 

I.         Standard of Review

            “In reviewing the trial court’s ruling on [an accused’s] federal constitutional speedy trial claim, we apply a bifurcated standard of review:  an abuse of discretion standard for the factual components, and a de novo standard for the legal components.”  Id. at 282 (quoting Zamorano v. State, 84 S.W.3d 643, 648 (Tex. Crim. App. 2002)).  Review of the Barker factors involves both legal and factual determinations, but “[t]he balancing test as a whole . . . is a purely legal question.”  Id. (quoting Zamorano, 84 S.W.3d at 648 n.19).  Under an abuse of discretion standard, we defer to the trial judge’s resolution of facts and reasonable inferences drawn therefrom, and we review the evidence in a light most favorable to the ruling.  Id.  

II.        Analysis of the Barker Factors

            A.         The Length of Delay

            The Barker test is triggered by a delay that is unreasonable enough to be considered presumptively prejudicial.  Id. at 281.  In this case, Hudson’s indictment was filed June 23, 2004, but no trial was conducted until July 2009.  A delay of approximately five years is presumptively prejudicial.  Id. (citing Phillips v. State, 650 S.W.2d 396, 399 (Tex. Crim. App. 1983), and Doggett v. United States, 505 U.S. 647, 651–52 n.1 (1992) (noting courts generally find delays approaching one year presumptively prejudicial)).  This factor weighs toward a finding that Hudson was denied a speedy trial.

            B.         Reason for the Delay

            When analyzing this prong of the Barker test, “different weights should be assigned to different reasons.”  Barker, 407 U.S. at 531.  Deliberate attempts to delay trial in order to hamper a defense is weighed heavily against the State.  Id.  More neutral reasons, such as negligence or overcrowded courts are weighed less heavily.  Id.  A valid reason for delay “should serve to justify appropriate delay.”  Id. 

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Related

Dickey v. Florida
398 U.S. 30 (Supreme Court, 1970)
Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
Dragoo v. State
96 S.W.3d 308 (Court of Criminal Appeals of Texas, 2003)
Phillips v. State
650 S.W.2d 396 (Court of Criminal Appeals of Texas, 1983)
State v. Munoz
991 S.W.2d 818 (Court of Criminal Appeals of Texas, 1999)
Dokter v. State
281 S.W.3d 152 (Court of Appeals of Texas, 2009)
Zamorano v. State
84 S.W.3d 643 (Court of Criminal Appeals of Texas, 2002)
Cantu v. State
253 S.W.3d 273 (Court of Criminal Appeals of Texas, 2008)
Phipps v. State
630 S.W.2d 942 (Court of Criminal Appeals of Texas, 1982)
Harris v. State
489 S.W.2d 303 (Court of Criminal Appeals of Texas, 1973)