Arthur Lee Jackson v. State

Court of Appeals of Texas·Decided June 20, 2013·No. 01-12-00656-CR·Published

Opinion

Opinion issued June 20, 2013

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-12-00656-CR ——————————— ARTHUR LEE JACKSON, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 174th District Court Harris County, Texas Trial Court Cause No. 1331423

MEMORANDUM OPINION

In 2009, a jury convicted Arthur Lee Jackson of murder and assessed

punishment at twenty years’ confinement. After the verdict, Jackson learned that

the State had withheld potentially exculpatory evidence—photographs and video of

a bloodspot at the scene of the murder that the State had linked to Jackson with DNA evidence. He moved for a new trial based on Brady v. Maryland, 373 U.S.

83, 83 S. Ct. 1194 (1963). The trial court granted Jackson’s motion for new trial.

Jackson subsequently filed a pretrial writ of habeas corpus, contending that a

second trial for the same offense violates his rights under the United States and

Texas Constitutions. The trial court denied relief. Jackson appeals, contending that

a second trial is barred by double jeopardy and violates his right to effective

assistance of counsel, due process, and due course of law. Finding no error, we

affirm.

Discussion

Standard of Review

We review the denial of a writ of habeas corpus for an abuse of discretion,

viewing the facts in the light most favorable to the trial court’s ruling. Ex parte

Wheeler, 203 S.W.3d 317, 324 (Tex. Crim. App. 2006).

Double Jeopardy

The Double Jeopardy Clauses of the United States and Texas Constitutions

prohibit subsequent prosecution for the same offense after acquittal or final

conviction. See State v. Lee, 15 S.W.3d 921, 928 (Tex. Crim. App. 2000); see also

U.S. CONST. amend. V; TEX. CONST. art. I, § 14. Double jeopardy does not bar the

State from seeking a retrial of an accused whose conviction for the same offense

has been set aside, unless the conviction was set aside due to insufficient evidence.

2 Ex parte Queen, 877 S.W.2d 752, 755 (Tex. Crim. App. 1994). By granting a

motion for new trial, setting aside the verdict, and vacating its judgment, a trial

court restores the case to its position before the earlier trial, and the initial jeopardy

continues. See Lofton v. State, 777 S.W.2d 96, 97 (Tex. Crim. App. 1989).

The trial court granted Jackson’s motion for new trial, because the

prosecutor had failed to disclose Brady evidence, and not due to insufficient

evidence. See Queen, 877 S.W.2d at 755. Because the trial court has restored the

case to its position before the former trial, jeopardy continues. See Lofton, 777

S.W.2d at 97.

Jackson responds that setting aside the verdict due to prosecutorial

misconduct post-trial is comparable to a prosecutor inducing a mistrial before the

verdict to avoid acquittal of the defendant. See Oregon v. Kennedy, 456 U.S. 667,

102 S. Ct. 2083 (1982). Double jeopardy bars a retrial if the prosecutor, through

his intentional or reckless misconduct, induces the defense to move for a mistrial to

avoid an acquittal. Kennedy, 456 U.S. at 676, 102 S. Ct. 2083; Ex parte Mitchell,

977 S.W.2d 575, 580 (Tex. Crim. App. 1997); Bauder v. State, 921 S.W.2d 696

(Tex. Crim. App. 1996).

We reject Jackson’s comparison to cases in which the prosecution engaged

in conduct intended to draw a mistrial to avoid an acquittal. Double jeopardy does

not bar a retrial if a trial proceeds to conclusion, resulting in a conviction, and the

3 conviction is later set aside due to procedural error and not a lack of evidence—

whether on appeal or by the trial court’s granting of a new trial. Ex parte Davis,

957 S.W.2d 9, 15 (Tex. Crim. App. 1997) (holding that jeopardy does not apply to

bar a retrial where defendant’s conviction is reversed on appeal due to

prosecutorial misconduct); Ex parte Legrand, 291 S.W.3d 31, 40–41 (Tex. App.—

Houston [14th Dist.] 2009, pet ref’d) (holding that jeopardy does not apply to bar

retrial where defendant’s motion for new trial is granted due to prosecutorial

misconduct).

In Legrand, the Fourteenth Court of Appeals held that the concerns

expressed in Kennedy about mistrials induced by the prosecution to avoid

acquittal—deprivation of the option to go to the first jury and potentially end the

dispute with an acquittal—are not present when the case is brought to conclusion

and the jury renders a verdict. Legrand, 291 S.W.3d at 40–41.

Similarly, in this case, the State’s misconduct in failing to disclose Brady

evidence caused the trial court to set aside the verdict. See Legrand, 291 S.W.3d at

40–41. The State did not induce a mistrial to avoid an acquittal. See Davis, 957

S.W.2d at 14–15. Instead, Jackson’s trial proceeded to a jury verdict, which could

have ended the dispute with an acquittal. See Legrand, 291 S.W.3d at 41.

Following Davis and Legrand, we hold that double jeopardy does not bar a retrial.

See Davis, 957 S.W.2d at 15; Legrand, 291 S.W.3d at 41.

4 Due Process, Due Course of Law, and Right to Counsel

The state’s failure to disclose evidence material to Jackson’s guilt or

punishment is a due process violation under Brady, 373 U.S. at 87, 83 S. Ct. at

1196–97. If the defendant’s due process rights have been violated, we examine the

record to identify any prejudice caused by the violation or adverse effect upon the

effectiveness of counsel’s representation; courts must tailor relief to appropriately

neutralize it. United States v. Morrison, 449 U.S. 361, 364, 101 S. Ct. 665, 667–68

(1981); Cook v. State, 940 S.W.2d 623, 627 (Tex. Crim. App. 1996). A new trial

generally remedies the State’s withholding of Brady evidence in a prior trial,

because the defendant may investigate and develop other potential defenses based

on the excluded evidence in the second trial. See Mitchell, 977 S.W.2d at 578;

Cook, 940 S.W.2d at 627–28.

Jackson was unable to examine the Brady evidence that the prosecution

withheld before the first trial, or to consult with an expert about its impact on his

defensive strategy. But Jackson may now hire an expert and examine the

previously excluded evidence, eliminating any prejudice caused by its previous

unavailability. See Cook, 940 S.W.2d at 628. Jackson also notes that he testified

during the trial in reliance on the then-existing state of the evidence. During a

second trial, Jackson may refuse to testify, and the trial court must fashion a

remedy limiting harm relating to the defendant’s decision to waive his Fifth

5 Amendment right and testify in the first trial. See Sweeten v. State, 693 S.W.2d

454, 457 (Tex. Crim. App.

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

Arthur Lee Jackson v. State, (Tex. Ct. App. 2013).

Arthur Lee Jackson v. State (Arthur Lee Jackson v. State) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Harrison v. United States
392 U.S. 219 (Supreme Court, 1968)
United States v. Morrison
449 U.S. 361 (Supreme Court, 1981)
Oregon v. Kennedy
456 U.S. 667 (Supreme Court, 1982)
Ex Parte Wheeler
203 S.W.3d 317 (Court of Criminal Appeals of Texas, 2006)
Ex Parte Legrand
291 S.W.3d 31 (Court of Appeals of Texas, 2009)
Bauder v. State
921 S.W.2d 696 (Court of Criminal Appeals of Texas, 1996)
Lofton v. State
777 S.W.2d 96 (Court of Criminal Appeals of Texas, 1989)
Cook v. State
940 S.W.2d 623 (Court of Criminal Appeals of Texas, 1996)
Sweeten v. State
693 S.W.2d 454 (Court of Criminal Appeals of Texas, 1985)
Ex Parte Mitchell
977 S.W.2d 575 (Court of Criminal Appeals of Texas, 1997)
State v. Lee
15 S.W.3d 921 (Court of Criminal Appeals of Texas, 2000)
Ex Parte Queen
877 S.W.2d 752 (Court of Criminal Appeals of Texas, 1994)
State v. Frye
897 S.W.2d 324 (Court of Criminal Appeals of Texas, 1995)
Ex Parte Davis
957 S.W.2d 9 (Court of Criminal Appeals of Texas, 1997)