Arnulfo Mercado-Pena, Jr. v. State

CourtCourt of Appeals of Texas
DecidedApril 7, 2020
Docket05-18-01008-CR
StatusPublished

This text of Arnulfo Mercado-Pena, Jr. v. State (Arnulfo Mercado-Pena, Jr. v. State) 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
Arnulfo Mercado-Pena, Jr. v. State, (Tex. Ct. App. 2020).

Opinion

Affirm and Opinion Filed April 7, 2020

In The Court of Appeals Fifth District of Texas at Dallas No. 05-18-01008-CR

ARNULFO MERCADO-PENA, JR., Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 296th Judicial District Court Collin County, Texas Trial Court Cause No. 296-84147-2017

MEMORANDUM OPINION Before Justices Pedersen, III, Reichek, and Carlyle Opinion by Justice Pedersen, III A jury found appellant Arnulfo Mercado-Pena guilty of evading arrest with a

motor vehicle, which jurors found was used as a deadly weapon. The trial court

assessed his punishment at sixty years’ confinement in the Institutional Division of

the Texas Department of Corrections. In three issues, appellant contends that (1) the

trial court violated his constitutional and statutory rights by failing to comply with

Chapter 46B of the Texas Code of Criminal Procedure, (2) the trial court erroneously

found him competent to proceed to trial, and (3) he was denied effective assistance

of counsel. We affirm. Background

A police officer was on patrol in Princeton, Texas when he observed appellant

driving a vehicle at a speed that appeared to be unreasonable and imprudent. The

officer, who was in a marked police car, turned on his overhead lights and siren and

pursued the vehicle. He testified that appellant was driving approximately 100 miles

per hour in a sixty mile-per-hour zone and was passing other cars in a dangerous

manner. Ultimately, appellant’s vehicle ran out of gas and slowed down. Appellant

jumped out and ran into a field. The officer followed and arrested him. Appellant

remained in custody after his arrest.

The proceedings prior to trial are of significance to our review. The case was

first set for trial on June 11, 2018. The record shows, however, that early on the

morning of June 11, appellant was found in his cell following a possible suicide

attempt.

Doctor Kristi Compton, a licensed psychologist, concluded that appellant was

not competent to stand trial that day because:

He is morbidly depressed. The suicide attempt was a lethal attempt. He was started on Risperdal four days ago, and it can take up to two to four weeks for it to have its effectiveness. Two weeks before, Dr. Compton had examined appellant1 and concluded that he was

malingering. However, she testified on June 11 that she was told he was unconscious

1 The record does not explain what triggered that examination. A Mental Illness Assessment was submitted on May 28, 2018 following this assessment. –2– when found and—while she had not performed malingering tests this time—she had

serious concerns about whether he was able to assist in his defense. She reminded

the court and those present that a person can be both mentally ill and malingering.

She did predict that—with hospitalization, drug therapy, and time for the drugs to

work—he could regain competency in two to four weeks. After conferring with

another mental health professional, the trial court ordered a continuance and returned

appellant to jail to continue his medicine regimen.

Pursuant to an order by the trial court, Dr. Compton conducted a

comprehensive competency evaluation of appellant on July 25, 2018. Her report

related that information on which she had earlier relied—specifically, that appellant

had lost consciousness in the June suicide attempt and required resuscitation—was

incorrect; she concluded that appellant had not intended the attempt to be fatal. And

as to his mental condition on July 25, she concluded:

[Appellant] demonstrated a sufficient understanding of his case, proceedings, and potential penalties. There is no evidence that he is suffering from a severe psychiatric disorder that impairs his capacity to communicate with his attorney, process information, weigh the pros and cons of various defense strategies, nor is there any evidence that he cannot testify in his own behalf. Thus, he exhibits sufficient capacity to assist in his defense if he chooses to do so. Based on these assessments, the doctor found appellant competent to stand trial.

Likewise, the trial court found that appellant was competent to stand trial, and

the trial went forward. The State called a single witness, the patrol officer who

arrested appellant. The defense rested without calling a witness. The jury found

–3– appellant guilty of evading arrest using a motor vehicle and found that he had used

the vehicle as a deadly weapon.

During the punishment phase of trial, the State admitted exhibits that

established appellant’s prior offenses for failure to render assistance, resisting arrest,

aggravated sexual assault of a child, aggravated assault causing serious bodily

injury, and failure to register as a sex offender.2 The State also offered testimony of

appellant’s gang membership.

Appellant’s sister testified on his behalf, explaining that he had a medical

history of seizures and that he had experienced one immediately before the incident

for which he was convicted. She testified that appellant had been released from

prison a matter of weeks before this incident, and she was not sure if he had obtained

the medications he needed.

Appellant’s counsel asked the trial court to assess a minimum sentence of

twenty-five years; the court sentenced appellant to sixty years. This appeal followed.

2 Because defense counsel had stipulated to the admissibility of the exhibits, a number of other offenses cited in motions to revoke were also admitted. –4– Competency to Stand Trial

Due process does not allow a criminal defendant who is incompetent to be put

to trial. Turner v. State, 422 S.W.3d 676, 688 (Tex. Crim. App. 2013). The

Legislature has codified procedures for determining competency to assure that

incompetent defendants do not stand trial. TEX. CODE CRIM. PROC. ANN. ch. 46B;

Boyett v. State, 545 S.W.3d 556, 563 (Tex. Crim. App. 2018). We review a trial

court’s actions under these procedures for an abuse of discretion. Routon v. State,

No. 05-15-01278-CR, 2017 WL 85417, at *3 (Tex. App.—Dallas Jan. 10, 2017, pet.

ref’d) (mem. op., not designated for pub.). We may not substitute our judgment for

that of the trial court; instead we ask whether the trial court’s decision was arbitrary

or unreasonable. Id.

We presume a criminal defendant is competent to stand trial unless he is

proved incompetent by a preponderance of the evidence. CRIM. PROC. art.

46B.003(b). The defendant is incompetent to stand trial if he lacks:

(1) sufficient present ability to consult with the person’s lawyer with a reasonable degree of rational understanding; or (2) a rational as well as factual understanding of the proceedings against the person.

Id. art. 46B.003(a). We give great deference to the trial court’s first-hand factual

assessment of a defendant’s competency and to its factual findings. See McDaniel v.

State, 98 S.W.3d 704, 713 (Tex. Crim. App. 2003).

–5– Following Chapter 46B Procedures

Appellant’s first issue argues that the trial court failed to comply with the

procedures set out in Chapter 46B of the Texas Code of Criminal Procedure

concerning incompetency to stand trial. Specifically, appellant contends that the trial

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Salinas v. State
163 S.W.3d 734 (Court of Criminal Appeals of Texas, 2005)
Bone v. State
77 S.W.3d 828 (Court of Criminal Appeals of Texas, 2002)
Mitchell v. State
68 S.W.3d 640 (Court of Criminal Appeals of Texas, 2002)
Thompson v. State
9 S.W.3d 808 (Court of Criminal Appeals of Texas, 1999)
Jackson v. State
877 S.W.2d 768 (Court of Criminal Appeals of Texas, 1994)
Turner, Albert James
422 S.W.3d 676 (Court of Criminal Appeals of Texas, 2013)
McDaniel v. State
98 S.W.3d 704 (Court of Criminal Appeals of Texas, 2003)
Ex parte Garcia
486 S.W.3d 565 (Court of Criminal Appeals of Texas, 2016)
Boyett v. State
545 S.W.3d 556 (Court of Criminal Appeals of Texas, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Arnulfo Mercado-Pena, Jr. v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arnulfo-mercado-pena-jr-v-state-texapp-2020.