Brandon Scott Bean v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJanuary 22, 2025
Docket09-23-00004-CR
StatusPublished

This text of Brandon Scott Bean v. the State of Texas (Brandon Scott Bean 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.

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Brandon Scott Bean v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-23-00004-CR __________________

BRANDON SCOTT BEAN, Appellant

V.

THE STATE OF TEXAS, Appellee

__________________________________________________________________

On Appeal from the 356th District Court Hardin County, Texas Trial Cause No. 23786 __________________________________________________________________

MEMORANDUM OPINION

Brandon Scott Bean appeals from the trial court’s denial of his motion to

suppress. After the trial court denied his motion to suppress, Bean pleaded guilty to

the offense of possession of a controlled substance. See Tex. Health & Safety Code

Ann. § 481.115(b). The trial court sentenced Bean to confinement for two years in

the Texas Department of Criminal Justice but suspended the sentence and placed

Bean on community supervision for five years. In one issue on appeal, Bean argues

that the trial court erred in failing to suppress evidence obtained from a police officer

1 when the videotape showing possession of the substance by Bean had been

destroyed. Bean argues that his due process rights were violated when the State

failed to preserve exculpatory and potentially useful evidence and the State’s failure

to preserve evidence was bad faith. We affirm.

Background

On June 5, 2018, Bean filed a pretrial motion to suppress methamphetamine,

other items seized from the stop, and any statements or admissions made by the

defendant. Bean alleged that his arrest and detention was made without warrant and

contrary to the Fourth Amendment of the United States Constitution, Article I,

Section 9 of the Texas Constitution and Chapter 14 of the Texas Code of Criminal

Procedure. He asked the trial court to suppress the fruits of this arrest and detention

pursuant to Article 38.23 of the Texas Code of Criminal Procedure.

On July 12, 2018, the trial court heard the motion to suppress. The State

presented one witness, Officer Chad Ainsworth with the Lumberton Police

Department. Ainsworth testified that on July 31, 2015, he saw Bean’s motorcycle

traveling with a defective taillight. Based on prior dealings in narcotics, Ainsworth

recognized the name Brandon Bean. He stopped the motorcycle and Bean gave him

consent to search his bag. As Ainsworth was patting him down for weapons, Bean

attempted to reach in his right pocket. After asking Bean to stop, Officer Ainsworth

reached in Bean’s pocket and felt a small plastic bag that was consistent with

2 narcotics. Bean admitted that the substance in the plastic bag was methamphetamine

and Ainsworth placed Bean under arrest.

Ainsworth testified his patrol car had audio and video the night of the stop.

He did not personally turn over the video to the District Attorney’s office because at

that time, he believed that a lieutenant would do that. The State acknowledged on

the record that no audio or video was turned over to Bean’s defense lawyer, but no

audio or video was included in the original case from Lumberton Police Department,

so they inquired with the department and were informed that in July 2015 the normal

course of business was to reuse or get rid of recordings after ninety-one days.

Because of that policy, there was no longer a recording of the stop.

Defense counsel argued that since only one officer was involved, the

destruction of the video recording constituted spoliation of exculpatory evidence

resulting in a denial of due process and dismissal was required. The defense did not

present evidence showing the video recording included any exculpatory evidence.

Defense counsel asked the trial court to hold its ruling in abeyance so that an affidavit

from the business record custodian from the Lumberton Police Department could be

obtained by the State. The State proffered that the chief of police informed the State

of the video retention policy.

On August 29, Bean filed a Memorandum in Support of Defendant’s Motion

to Suppress. On September 10, 2018, the parties continued the motion to suppress

3 hearing and presented their arguments. The trial court took the issue under

advisement and on September 12 issued its order denying Bean’s motion to suppress.

Standard of Review and Applicable Law

We review a trial court’s ruling on a motion to suppress using a bifurcated

standard of review. State v. Kerwick, 393 S.W.3d 270, 273 (Tex. Crim. App. 2013).

Id.; Guzman v. State, 955 S.W.2d 85, 89 (Tex. Crim. App. 1997). However, we

review de novo questions of law and mixed questions of law and fact that do not rely

on credibility determinations. Kerwick, 393 S.W.3d at 273. At a hearing on a motion

to suppress, the trial court is the exclusive trier of fact and judge of the credibility of

the witnesses. Maxwell v. State, 73 S.W.3d 278, 281 (Tex. Crim. App. 2002). A trial

court may choose to believe or to disbelieve any part of a witness’s testimony. State

v. Ross, 32 S.W.3d 853, 855 (Tex. Crim. App. 2000), modified on other grounds by

State v. Cullen, 195 S.W.3d 696 (Tex. Crim. App. 2006). We must uphold the trial

court’s ruling on a motion to suppress if the ruling was supported by the record and

was correct under any theory of law applicable to the case. Armendariz v. State, 123

S.W.3d 401, 404 (Tex. Crim. App. 2003).

The Due Process Clause of the Fourteenth Amendment guarantees a

defendant in a criminal prosecution a trial comporting with fundamental fairness.

See California v. Trombetta, 467 U.S. 479, 485 (1984). In determining whether the

failure to preserve evidence violated a defendant’s due process rights, courts have

4 drawn a distinction between lost or missing evidence that can be considered

“material exculpatory evidence” and evidence that is at best “potentially useful.” Ex

parte Napper, 322 S.W.3d 202, 229, 231 (Tex. Crim. App. 2010) (citing Arizona v.

Youngblood, 488 U.S. 51, 57-58 (1988)). A federal due process violation occurs

whenever the State suppresses or fails to disclose material, exculpatory evidence,

regardless of whether the State acted in bad faith. Illinois v. Fisher, 540 U.S. 544,

547-48 (2004); see also Ex parte Napper, 322 S.W.3d at 229 (citing Youngblood,

488 U.S. at 57). However, if a defendant seeks to prove a federal due process

violation based on the State’s destruction of potentially useful evidence, the

defendant must show the State acted in bad faith in destroying the evidence. Fisher,

540 U.S. at 547-48; Youngblood, 488 U.S. at 57-58; Ex parte Napper, 322 S.W.3d

at 229; see also Neal v. State, 256 S.W.3d 264, 280 (Tex. Crim. App. 2008)

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Related

California v. Trombetta
467 U.S. 479 (Supreme Court, 1984)
Arizona v. Youngblood
488 U.S. 51 (Supreme Court, 1989)
Illinois v. Fisher
540 U.S. 544 (Supreme Court, 2004)
Armendariz v. State
123 S.W.3d 401 (Court of Criminal Appeals of Texas, 2003)
State v. Cullen
195 S.W.3d 696 (Court of Criminal Appeals of Texas, 2006)
Maxwell v. State
73 S.W.3d 278 (Court of Criminal Appeals of Texas, 2002)
State v. Ross
32 S.W.3d 853 (Court of Criminal Appeals of Texas, 2000)
Ex Parte Napper
322 S.W.3d 202 (Court of Criminal Appeals of Texas, 2010)
Neal v. State
256 S.W.3d 264 (Court of Criminal Appeals of Texas, 2008)
Guzman v. State
955 S.W.2d 85 (Court of Criminal Appeals of Texas, 1997)
State of Texas v. Kerwick, Stacie Michelle
393 S.W.3d 270 (Court of Criminal Appeals of Texas, 2013)

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