Brian Keith Loud v. State

CourtCourt of Appeals of Texas
DecidedFebruary 8, 2012
Docket10-11-00063-CR
StatusPublished

This text of Brian Keith Loud v. State (Brian Keith Loud 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
Brian Keith Loud v. State, (Tex. Ct. App. 2012).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-11-00063-CR

BRIAN KEITH LOUD, Appellant v.

THE STATE OF TEXAS, Appellee

From the 361st District Court Brazos County, Texas Trial Court No. 10-02171-CRF-361

MEMORANDUM OPINION

The jury convicted Brian Loud of the offense of robbery, found the enhancement

paragraphs to be true, and assessed his punishment at confinement for life. We affirm.

Background Facts

There is no challenge to the sufficiency of the evidence. Cassie Bailey, a bank

teller at Wells Fargo Bank, testified at trial that on the morning of February 2, 2010 a

man came into the bank and handed her a note that said: I have a gun, I don’t want to hurt you, keep your hands where I can see them put the money in here. Anything goes wrong before I’m out the door. I’ll kill you!

Bailey gave the man all of the money out of her drawer, and the man left the bank.

Bailey identified Loud at trial as the person who robbed the bank.

Detective Lance Matthews testified that he received information naming Loud as

a possible suspect in the robbery and giving an address where Loud could be located.

Detective Matthews went to the residence, and Loud’s brother answered the door.

Detective Matthews stated that upon entering the residence, he saw Loud down on his

knees with his hands in the air. Loud voluntarily talked to Detective Matthews and

denied being involved in the robbery. Detective Matthews received consent to search

the residence. He found a black hoodie, black knit cap, and black pants matching those

worn by the suspect as seen on surveillance video from the bank.

Detective Matthews obtained an arrest warrant, and Loud was placed under

arrest. In an interview the following day, Loud admitted robbing the bank, but

indicated that he did so at the request of another individual. Loud told the detective

that they planned to use the money to buy drugs and then sell the drugs to “double” or

“triple” the amount of money.

Competency to Stand Trial

In his first issue, Loud complains that the trial court erred in not conducting a

sua sponte informal inquiry into his competency. A person is incompetent to stand trial

if the person does not have sufficient present ability to consult with counsel with a

reasonable degree of rational understanding; or a rational as well as factual

Loud v. State Page 2 understanding of the proceedings against him. TEX. CODE CRIM. PRO. ANN. art. 46B.003

(West 2006). Either party may suggest by motion, or the trial court may suggest on its

own motion, that the defendant may be incompetent to stand trial. TEX. CODE CRIM.

PRO. ANN. art. 46B.004 (a) (West Supp. 2011).1 If evidence suggesting the defendant

may be incompetent to stand trial comes to the attention of the court, the court on its

own motion shall suggest that the defendant may be incompetent to stand trial. TEX.

CODE CRIM. PRO. ANN. art. 46B.004 (b) (West Supp. 2011). On suggestion that the

defendant may be incompetent to stand trial, the court shall determine by informal

inquiry whether there is some evidence from any source that would support a finding

that the defendant may be incompetent to stand trial. TEX. CODE CRIM. PRO. ANN. art.

46B.004 (c) (West Supp. 2011).

An inquiry into competency must be conducted when there is evidence

sufficient to raise a bona fide doubt in the mind of the judge whether the defendant is

legally competent. Gonzales v. State, 313 S.W.3d 840, 842 (Tex. Crim. App. 2010). A bona

fide doubt may exist if the defendant exhibits truly bizarre behavior or has a recent

history of severe mental illness or at least moderate mental retardation. Id. We review

a trial court's failure to conduct a competency inquiry under an abuse of discretion

standard. Moore v. State, 999 S.W.2d 385, 393 (Tex. Crim. App. 1999).

Loud first argues that his behavior when the police arrived at his brother’s

residence to investigate the offense is evidence of bizarre behavior. Loud was on his

1TEX. CODE CRIM. PRO. ANN. art. 46B.004 was amended effective September 1, 2011. The changes apply only to proceedings conducted after September 1, 2011. Because Loud was tried in February 2011, the new provisions are not applicable in this case.

Loud v. State Page 3 knees with his hands in the air. We do not find Loud’s apparent submission to police

authority to be an exhibition of truly bizarre behavior.

Loud next argues that his confession indicates that he is easily influenced by

others and demonstrates incompetence. We do not find that the circumstances of

Loud’s confession are sufficient to raise a bona fide doubt as to his competency.

Loud further argues that the evidence of his mental health issues is sufficient

evidence for the trial court to conduct a sua sponte inquiry into his competence. Loud

presented evidence that he was housed in the medical section of the Brazos County Jail

and that he was taking medicine for mental health issues. Evidence that Loud was on

psychiatric medication and had a history of mental problems did not mandate a

competency inquiry absent evidence of a present inability to communicate or

understand the proceedings. Moore v. State, 999 S.W.2d at 395-96; LaHood v. State, 171

S.W.3d 613, 619 (Tex. App.─Houston [14th Dist.] 2005, pet. ref’d).

The record does not support a finding that Loud was unable to communicate or

understand the proceedings. The record shows that Loud and his counsel discussed

whether Loud should testify at trial and that Loud decided against testifying. The

record further shows that Loud and his counsel discussed trial strategy on a possible

defense. Loud responded appropriately when questioned by counsel. The trial court

did not abuse its discretion in failing to conduct a sua sponte informal inquiry into

Loud’s competency. We overrule the first issue.

Loud v. State Page 4 Batson Challenge

In his second issue, Loud argues that the State used its peremptory challenges to

eliminate all African-Americans from the jury and did not give a racially neutral

explanation for the challenges pursuant to Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712,

90 L.Ed.2d 69 (1986). In Batson, the United States Supreme Court held that, while a

prosecutor ordinarily may exercise peremptory strikes for any reason related to his

views concerning the outcome of the trial, "the Equal Protection Clause forbids the

prosecutor to challenge potential jurors solely on account of their race." Grant v. State,

325 S.W.3d 655, 657 (Tex. Crim. App. 2010). A Batson challenge to a peremptory strike

consists of three steps: 1) the opponent of the strike must establish a prima facie

showing of racial discrimination; 2) the proponent of the strike must articulate a race-

neutral explanation; and 3) the trial court must decide whether the opponent has

proven purposeful racial discrimination. Id.

The trial court's ruling in the third step must be sustained on appeal unless it is

clearly erroneous. Id. Because the trial court's ruling requires an evaluation of the

credibility and demeanor of prosecutors and venire members, and because this

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Related

Batson v. Kentucky
476 U.S. 79 (Supreme Court, 1986)
LaHood v. State
171 S.W.3d 613 (Court of Appeals of Texas, 2005)
Moore v. State
999 S.W.2d 385 (Court of Criminal Appeals of Texas, 1999)
Gonzales v. State
313 S.W.3d 840 (Court of Criminal Appeals of Texas, 2010)
Grant v. State
325 S.W.3d 655 (Court of Criminal Appeals of Texas, 2010)

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