Buchanan v. State

807 S.W.2d 644, 1991 Tex. App. LEXIS 762, 1991 WL 41038
CourtCourt of Appeals of Texas
DecidedMarch 28, 1991
DocketB14-90-00557-CR, B14-90-0554-CR
StatusPublished
Cited by18 cases

This text of 807 S.W.2d 644 (Buchanan 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
Buchanan v. State, 807 S.W.2d 644, 1991 Tex. App. LEXIS 762, 1991 WL 41038 (Tex. Ct. App. 1991).

Opinions

MAJORITY OPINION

JUNELL, Justice.

A jury convicted appellant of the offenses of unauthorized use of a motor vehicle (Cause No. 19,086-272) and theft (Cause No. 19,087-272) and the trial court assessed punishment at ten years in each cause, sentences to run concurrently, in the Institutional Division of the Texas Department of Criminal Justice. Appellant brings two points of error alleging: (1) the trial court erred in allowing the jury to submit written questions which were propounded to the witnesses, allowing the jurors to become advocates rather than impartial finders of fact; and (2) insufficient evidence to support the conviction. We affirm.

In his first point of error appellant contends that the trial court erred in allowing the jury to formulate questions which the judge propounded to the specific witness. Appellant asserts that such a practice allows the jurors to become advocates rather than finders of fact. We disagree.

In this instance, the trial court, after a witness had been questioned by the prosecution and defense attorneys, asked the jurors if they had any questions to ask the witnesses. The trial judge had the jurors write down their questions on paper. The jury then retired to the jury room. Outside the jury’s presence, the trial judge read the questions and allowed the attorneys to pose any objections, e.g. hearsay, relevancy, etc. The only objection made was made by appellant’s trial counsel: he objected to the entire process. This objection was overruled. The jury then returned to the courtroom where the judge asked the witness the question(s) tendered. When the trial judge completed the questions, he allowed the attorneys to ask follow-up questions before the witness was excused.

The issue of jurors questioning witnesses appears to be a rather unexplored one in Texas. However, the case law of other states is replete with information concerning the issue. See, e.g., State v. Lemaster, 137 Ariz. 159, 669 P.2d 592, 598 (App.1983); Nelson v. State, 257 Ark. 1, 513 S.W.2d 496, 498 (1974); Ferrara v. State, 101 So.2d 797, 801 (Fla.1958); Sparks v. Daniel, 343 S.W.2d 661, 667 (Mo.App.1961); People v. Knapper, 230 A.D. 487, 245 N.Y.S. 245, 251 (1930); State v. Kendall, 143 N.C. 659, 57 S.E. 340, 341 (1907); Byrge v. State, 575 S.W.2d 292, 295 (Tenn.Crim.App.1978); State v. Johnson, 784 P.2d 1135, 1144-1145 (Utah 1989). These states hold the general rule is that it is within the discretion of the trial court whether to allow jurors to ask questions of witnesses. Such a rule is consistent with the rules in Texas governing the mode and order of interrogation of witnesses and presentation of evidence.

Tex.R.CRIM.Evid. 610(a) states, in pertinent part:

The court shall exercise reasonable control over the mode and order of interrogating witnesses and presenting evidence so as to (1) make the interrogation and presentation effective for the ascertainment of the truth.

Thus, in Texas, the trial court has the task of controlling the mode of questioning witnesses. Nowhere in the rules is it stated that the jury is forbidden to ask questions of the witnesses. In fact, the Texas Court of Criminal Appeals, when presented with the question nearly twenty years ago, did not denounce the idea when given the opportunity. Carr v. State, 475 S.W.2d 755, 757 (Tex.Crim.App.1972). Though the Court of Criminal Appeals in Carr stated that appellant had presented a multifarious ground of error and presented nothing for review, the court went on and discussed the fact that a juror or jurors had been permitted to ask questions of a witness. Id. Carr, acting pro se, failed to object to the procedure and the court stated that it was impossible to see how the defendant was harmed. Id. The court could have condemned the entire procedure regarding jurors questioning witnesses. It chose not to do so. We find this telling.

[646]*646While here, appellant’s counsel did object, it is still impossible to find that the procedure harmed the appellant in any way. He seems to argue that the jury asked questions which helped the prosecution build its case. Is he then arguing that if the jury asked questions which seemed to harm the state’s case or help his there would be no problem? The questions asked in this case were not especially dangerous or helpful to either side. Considering the procedural safeguards provided by the trial court in the manner of the questioning we fail to see any abuse of discretion on the part of the trial court.

As stated by the Fifth Circuit:

There is nothing improper about the practice of allowing occasional questions from jurors to be asked of witnesses. If a juror is unclear as to a point in the proof, it makes good common sense to allow a question to be asked about it. If nothing else, the question should alert trial counsel that a particular factual issue may need more extensive development. Trials exist to develop the truth.

United States v. Callahan, 588 F.2d 1078, 1086 (5th Cir.), cert. denied, 444 U.S. 826, 100 S.Ct. 49, 62 L.Ed.2d 33 (1979). The reasoning of the Fifth Circuit is sound. The days of trial by ambush are long past. In this case, appellant was afforded great procedural protection in the manner in which the questioning was conducted. The trial court required the jurors to write down the questions and then retired them to the jury room to give the attorneys the opportunity to object to the questions. Only then did the trial court return the jury and ask the questions propounded by the jurors. The court also permitted each attorney to ask questions of each witness after the jurors’ questions were asked. The questioning was not overly extensive and did not consume an inordinate amount of time. With these procedural protections, there was no harm and no reversible error. Appellant’s first point of error is overruled.

In his second point of error the appellant alleges that the evidence is insufficient to sustain his conviction. Specifically, appellant contends that the evidence failed to show that his use of the motor vehicle in question was without the effective consent of the owner.

Appellant was charged under Tex.Penal Code Ann. § 1.07(a)(9) and § 31.07 which provides: “a person commits an offense if he intentionally or knowingly operates another’s motor-propelled vehicle without the effective consent of the owner.” “Effective consent” is defined as assent in fact, whether express or apparent, and includes consent by a person legally authorized to act for the owner. Tex.Penal Code Ann. § 31.01(4).

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Bluebook (online)
807 S.W.2d 644, 1991 Tex. App. LEXIS 762, 1991 WL 41038, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buchanan-v-state-texapp-1991.