Arturo Vargas v. State

CourtCourt of Appeals of Texas
DecidedApril 15, 2010
Docket03-08-00508-CR
StatusPublished

This text of Arturo Vargas v. State (Arturo Vargas 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
Arturo Vargas v. State, (Tex. Ct. App. 2010).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-08-00508-CR

Arturo Vargas, Appellant



v.



The State of Texas, Appellee



FROM THE DISTRICT COURT OF MILAM COUNTY, 20TH JUDICIAL DISTRICT

NO. CR21657, HONORABLE ED MAGRE, JUDGE PRESIDING

M E M O R A N D U M O P I N I O N



Arturo Vargas was arrested and charged with the crime of burglary of a habitation. See Tex. Penal Code Ann. § 30.02(a) (West 2003) (listing elements for offense). Deputy Jonathan Beathard was the investigating officer who arrested Vargas. Ultimately, a trial was scheduled, and Vargas elected to have the jury determine his guilt and to have the district court determine his punishment. The jury found him guilty. During the punishment hearing, the State alleged, for punishment-enhancement purposes, that Vargas had been convicted of two prior felonies: murder and manslaughter. See id. § 12.42(d) (West Supp. 2009) (elevating permissible punishment range for repeat felony offenders). Vargas pleaded not true to the allegations, and the State introduced evidence regarding the alleged prior crimes. At the end of the hearing, the court found both allegations true and sentenced Vargas to 25 years' imprisonment. On appeal, Vargas challenges the district court's determination regarding the alleged prior convictions. We will affirm the judgment of the district court.



DISCUSSION

In one issue on appeal, Vargas contends that the evidence pertaining to the prior felony convictions is "legally and factually insufficient to specifically link [him] to the prior convictions for purposes of the enhancement allegations."

Before a prior conviction may properly be used to enhance a defendant's punishment, "the State must prove beyond a reasonable doubt that (1) a prior conviction exists, and (2) the defendant is linked to that conviction." (1) Flowers v. State, 220 S.W.3d 919, 921 (Tex. Crim. App. 2007); see Davis v. State, 268 S.W.3d 683, 715 (Tex. App.--Fort Worth 2008, pet. ref'd). Although the State must "show by independent evidence that the defendant" was the person previously convicted, there is no specific manner by which the State must link prior convictions to a defendant. See Beck v. State, 719 S.W.2d 205, 209-10 (Tex. Crim. App. 1986); see also Flowers, 220 S.W.3d at 922 (explaining that "[a]ny type of evidence, documentary or testimonial, might suffice"). Usually, the State will offer "certified copies of a judgment and a sentence and authenticated copies of the Texas Department of Corrections records including fingerprints." Beck, 719 S.W.2d at 209. This type of information is often called a "pen pack," Davis, 268 S.W.3d at 715, but the admission of pen packs is "not normally sufficient standing alone . . . even if the name on the . . . pen packet is the same as the defendant at trial," see Beck, 719 S.W.2d at 210; see also Zimmer v. State, 989 S.W.2d 48, 50 (Tex. App.--San Antonio 1998, pet. ref'd) (noting need for evidence of identity in addition to pen packs). For this reason, the State usually also offers additional linking information. Although there is no exhaustive list for the methods by which the link may be established, courts have identified several ways in which the link has been made, including the following: admitting "expert testimony identifying" the fingerprints from the prior convictions "as identical with known fingerprints of the defendant," eliciting "testimony of a witness who personally knows the defendant and the fact of his prior conviction and identifies him," obtaining an admission from the defendant, "matching a photograph of the defendant in a [pen pack] . . . to the defendant at trial," or using a combination of these methods. Beck, 719 S.W.2d at 209-10; Zimmer, 989 S.W.2d at 50.

When determining the sufficiency of the evidence, courts must bear in mind that the evidence used to link a prior crime to a defendant often "resembles a jigsaw puzzle." Human v. State, 749 S.W.2d 832, 835-36 (Tex. Crim. App. 1988) (op. on reh'g). Stated differently, "[t]he pieces standing alone usually have little meaning. However, when the pieces are fitted together, they usually form the picture of the person who committed the alleged prior conviction or convictions." Id. at 836. Moreover, the court must be aware that the "trier of fact fits the pieces of the jigsaw puzzle together and weighs the credibility of each piece" and that "the trier of fact determines if these pieces fit together sufficiently to complete the puzzle." Flowers, 220 S.W.3d at 923; see also Johnson v. State, 23 S.W.3d 1, 7 (Tex. Crim. App. 2000) (explaining that under factual-sufficiency review, fact finder is sole judge of weight and credibility of evidence presented); Jones v. State, 944 S.W.2d 642, 647 (Tex. Crim. App. 1996) (noting that under legal-sufficiency review, trier of fact is entitled to determine what weight to give any particular evidence, to resolve conflicts in evidence, and to evaluate credibility of witnesses).

In reviewing the legal sufficiency of the evidence presented at trial, a reviewing court must view all of the evidence in the light most favorable to the State. Villarreal v. State, 286 S.W.3d 321, 327 (Tex. Crim. App. 2009). The evidence is legally sufficient if based on "the totality of the evidence," the trier of fact could determine beyond a reasonable doubt that there was a previous conviction and that the defendant was the one convicted. Flowers, 220 S.W.3d at 923. Unlike for legal-sufficiency reviews, in factual-sufficiency determinations, all of the evidence is considered in a neutral light. Watson v. State, 204 S.W.3d 404, 414 (Tex. Crim. App. 2006). The evidence is factually insufficient only if it is so weak that the trial court's determination "seems clearly wrong and manifestly unjust" or if the determination is "against the great weight and preponderance of the evidence." Id. at 414-15.

In this case, the State attempted to link Vargas to two prior convictions by admitting the pen packs for those prior crimes and through the testimony of Vargas's brother (Camilo Vargas) and Deputy Beathard who investigated the burglary at issue in this case. The packs include the judgments prepared for the prior crimes, photos of the individual adjudicated guilty in those crimes, and biographical information for that individual.

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Related

Watson v. State
204 S.W.3d 404 (Court of Criminal Appeals of Texas, 2006)
Davis v. State
268 S.W.3d 683 (Court of Appeals of Texas, 2008)
Villarreal v. State
286 S.W.3d 321 (Court of Criminal Appeals of Texas, 2009)
Flowers v. State
220 S.W.3d 919 (Court of Criminal Appeals of Texas, 2007)
Johnson v. State
23 S.W.3d 1 (Court of Criminal Appeals of Texas, 2000)
Beck v. State
719 S.W.2d 205 (Court of Criminal Appeals of Texas, 1986)
Jones v. State
944 S.W.2d 642 (Court of Criminal Appeals of Texas, 1996)
Zimmer v. State
989 S.W.2d 48 (Court of Appeals of Texas, 1999)
Human v. State
749 S.W.2d 832 (Court of Criminal Appeals of Texas, 1988)

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Arturo Vargas v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arturo-vargas-v-state-texapp-2010.