Carlos Oliva v. State

CourtCourt of Appeals of Texas
DecidedApril 2, 2014
Docket04-12-00674-CR
StatusPublished

This text of Carlos Oliva v. State (Carlos Oliva 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
Carlos Oliva v. State, (Tex. Ct. App. 2014).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION No. 04-12-00674-CR

Carlos OLIVA, Appellant

v. The State The STATE of Texas, Appellee

From the County Court at Law No. 2, Guadalupe County, Texas Trial Court No. CCL-10-1438 Honorable Frank Follis, Judge Presiding

Opinion by: Marialyn Barnard, Justice

Sitting: Catherine Stone, Chief Justice Marialyn Barnard, Justice Patricia O. Alvarez, Justice

Delivered and Filed: April 2, 2014

AFFIRMED

A jury convicted appellant Carlos Oliva of driving while intoxicated (“DWI”). The trial

court sentenced Oliva to 180 days confinement in the Guadalupe County Jail and assessed a

$2,000.00 fine. Confinement and half of the fine were probated for eighteen months. On appeal,

Oliva raises three issues contending the trial court erred by: (1) excluding Oliva’s field sobriety

test expert; (2) excluding Oliva’s medical records; and (3) overruling Oliva’s objections to the

State’s alleged improper jury argument. We affirm the trial court’s judgment. 04-12-00674-CR

BACKGROUND

Trooper Rudolph L. Williams of the Texas Department of Public Safety stopped a vehicle

driven by Oliva at shortly after 1:00 a.m. for speeding ten miles per hour over the speed limit.

While talking to Oliva and requesting his driver’s license and insurance, Trooper Williams noticed

an odor of alcohol emanating from Oliva. Oliva was asked if he had any alcoholic beverages to

drink that evening and answered he had not. Trooper Williams then decided to have Oliva perform

the three standardized field sobriety tests.

Trooper Williams administered the Horizontal Gaze and Nystagmus Test (“HGN” test),

the Walk and Turn Test, and the One-Leg Stand Test on Oliva at the scene. At no time during the

testing did Oliva inform Trooper Williams that he had suffered injuries to his lower back and legs.

Oliva’s results on each field sobriety test indicated to the trooper that Oliva was intoxicated.

Trooper Williams arrested Oliva based on the standardized field sobriety test results.

Oliva’s actual blood alcohol content on the night of his arrest was never determined

because he refused to submit to a Breathalyzer examination. Trooper Williams did not attempt to

obtain a warrant for a blood draw.

At trial, Trooper Williams testified to the events described above and also demonstrated to

the jury how two of the three standardized field sobriety tests are administered – the Walk and

Turn Test and the One-Leg Stand Test. The jury was subsequently shown video from the trooper’s

dash camera, which showed Oliva performing the field sobriety tests on the night of his arrest.

On cross-examination, Trooper Williams admitted he did not ask Oliva if he had any

preexisting physical injuries before administering the Walk and Turn and One-Leg Stand Tests.

Counsel for Oliva then asked Trooper Williams to administer the tests to Oliva in the presence of

the jury. Oliva’s performance of the field sobriety tests in front of the jury produced several

positive clues for intoxication even though he testified he had not consumed any alcohol that day. -2- 04-12-00674-CR

The next witness to testify was Oliva’s wife, Jacqueline Oliva. Ms. Oliva admitted,

contrary to her husband’s claim to the trooper, she and her husband had been drinking on the night

of Oliva’s arrest. She claimed, however, they consumed only two glasses of wine each. She also

testified about her husband’s military service with the Guatemalan military in the 1980s, and the

injuries he sustained during his service. According to Ms. Oliva, Oliva suffers from ankle and

knee injuries sustained as a result of helicopter jumps. She also testified Oliva suffered a gunshot

wound to his upper thigh. According to Ms. Oliva, these injuries affect Oliva’s mobility and ability

to walk a straight line.

After his wife testified about his injuries and disabilities, Oliva attempted to call Jerry

Potter, a former United States Navy military police officer, as an expert witness. In response, the

State requested a Daubert hearing, contending Mr. Potter was not a proper expert witness. During

the Daubert hearing, Mr. Potter testified he had served seventeen years as a military police officer,

was a field sobriety test instructor in the Navy, and had made in excess of 200 arrests during his

service. Oliva’s sole purpose in calling Mr. Potter as a proposed expert was to allow Mr. Potter to

opine that based on his experience, an officer performing field sobriety tests must ask the suspect

if he has any injuries that may affect his ability to perform the tests. After cross-examining Mr.

Potter, the State moved to exclude him as an expert witness.

The trial court declined to allow Mr. Potter to testify as an expert witness, stating: (1) “I do

not find that the question of whether an officer should ask someone about prior injuries before

administering field sobriety tests is a scientific or technical question;” (2) “Mr. Potter has

demonstrated no specialized training or qualifications in that field for that particular question;”

and (3) “it’s basically a matter of common sense . . . whether you would expect an officer to ask

someone if they were injured.”

-3- 04-12-00674-CR

After failing in his attempt to have Mr. Potter testify as an expert witness, Oliva called a

custodian of records to authenticate certain medical records. Oliva wanted to have the trial court

admit into evidence medical records regarding the diagnosis and treatment of his injuries.

The State objected to the introduction of Oliva’s medical records on the ground that they

are irrelevant without a physician’s testimony. According to the State, a doctor was necessary to

explain the technical language in the records that allegedly diagnosed Oliva’s injuries. The trial

court sustained the State’s objection, noting the medical records would be cumulative of evidence

already before the jury. Thereafter, Oliva took the stand to testify to the events leading up to his

arrest and his history of physical injury.

Oliva admitted consuming two or three drinks on the night of his arrest — despite telling

Trooper Williams otherwise. He told the jury his version of the events at the traffic stop, and the

origin of his injuries that allegedly affected his ability to pass some of the standardized field

sobriety tests. According to Oliva, he served in the Guatemalan Special Forces during the early

1980s. During his service, Oliva jumped from helicopters an estimated “36-40” times, which

caused ankle and knee damage. He also stated he suffered gunshot wounds to his upper leg and

his buttocks. As a result of these injuries, Oliva stated he had sciatic nerve damage and mobility

issues.

After Oliva testified, both sides delivered closing arguments. After deliberations, the jury

found Oliva guilty of DWI, and the trial court sentenced Oliva to 180 days confinement in the

Guadalupe County Jail and a $2,000 fine. As noted above, the jail time and half the fine were

probated. Oliva subsequently perfected this appeal.

-4- 04-12-00674-CR

ANALYSIS

As noted above, Oliva raises three issues on appeal. Specifically, Oliva contends the trial

court erred by: (1) excluding Mr. Potter’s testimony; (2) excluding his medical records; and (3)

overruling his objections to the State’s allegedly improper jury argument.

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