Carmouche, Monica Ann v. State

CourtCourt of Appeals of Texas
DecidedDecember 14, 2004
Docket14-03-00768-CR
StatusPublished

This text of Carmouche, Monica Ann v. State (Carmouche, Monica Ann 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
Carmouche, Monica Ann v. State, (Tex. Ct. App. 2004).

Opinion

Affirmed and Memorandum Opinion filed December 14, 2004

Affirmed and Memorandum Opinion filed December 14, 2004.

In The

Fourteenth Court of Appeals

_______________

NO. 14-03-00768-CR

MONICA ANN CARMOUCHE, Appellant

V.

THE STATE OF TEXAS, Appellee

______________________________________________________

On Appeal from County Criminal Court at Law No. 6

Harris County, Texas

Trial Court Cause No. 1143007

M E M O R A N D U M   O P I N I O N

Appellant Monica Ann Carmouche was charged by information with misdemeanor assault and convicted by a jury.  The jury assessed punishment at 300 days= confinement in the Harris County jail and a $500 fine.  In one issue, appellant contends the trial court erred in admitting records of two medical facilities because the State failed to establish the proper predicate for admission of these documents under the business records exception to the hearsay rule.  We agree; however, because we conclude the admission of the records was harmless error, we affirm the judgment of the trial court.


I.  Factual Background

In May 2002, Tambra Stickney sought to involuntarily commit her son Joshua to a drug treatment program and requested a mental health warrant for his arrest.  At the time, Joshua was staying with his father, Steve Stickney, and appellant, his father=s girlfriend.  The warrant was executed by constables on May 25, 2002, without Steve Stickney=s or appellant=s knowledge.  That evening, when appellant went to Tambra=s apartment looking for Joshua, an altercation between the two women ensued.  Tambra suffered bruises and a broken arm as a result of the altercation, and she was taken by ambulance to the hospital.

After a jury convicted appellant and assessed punishment, this appeal followed.

II.  Issue Presented and Standard of Review

In her sole issue, appellant contends the trial court erred in admitting the business records of two medical facilities, St. Catherine and Memorial hospitals, as the business records of a third unrelated medical facility, Orthopedic Associates (AO.A.@).  Appellant argues the records were improperly admitted because the State failed to offer them through the testimony of a qualified witness or by affidavit as required by Rule of Evidence 803(6), and, therefore, the records are inadmissible hearsay.  See Tex. R. Evid. 803(6).

A trial court has broad discretion regarding the admissibility of evidence, and we reverse only upon a showing of a clear abuse of that discretion.  West v. State, 124 S.W.3d 732, 734 (Tex. App.CHouston [1st Dist.] 2003, no pet.).  An abuse of discretion occurs when a trial court acts without reference to guiding rules or principles, or acts arbitrarily or unreasonably.  Galliford v. State, 101 S.W.3d 600, 604 (Tex. App.CHouston [1st Dist.] 2003, pet. ref=d).  When there is evidence supporting the trial court=s decision to admit evidence, there is no abuse and the reviewing court defers to that decision.  Osbourn v. State, 92 S.W.3d 531, 537B38 (Tex. Crim. App. 2002).


A.  Did the Trial Court Err in Admitting the Medical Records?

During trial the State offered into evidence, as Exhibit 5, Tambra=s medical records from O.A.; however, in addition to the records from O.A., Exhibit 5 contained Tambra=s medical records from St. Catherine and Memorial hospitals.  The exhibit was offered in its entirety as the business records of O.A. through an affidavit signed by O.A.=s custodian of records.  Appellant=s trial counsel objected, stating that the records from St. Catherine and Memorial were inadmissible hearsay within hearsay because they were not part of the regularly conducted business activities of O.A., and the State had failed to establish an exception to the hearsay rule allowing for their admission.[1]  The trial court overruled the objection.


Rule of Evidence 803(6) provides an exception to the hearsay rule for business records if the offering party shows (1) the records were made and kept in the regular course of business; (2) the business kept the records as part of its regular practice; (3) the records were made at or near the time of the event they contain; and (4) the person making the records or submitting the information had personal knowledge of the events being recorded.  See Tex. R. Evid. 803(6);[2] Philpot v. State, 897 S.W.2d 848, 851B52 (Tex. App.CDallas 1995, pet. ref=d). 

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Galliford v. State
101 S.W.3d 600 (Court of Appeals of Texas, 2003)
Osbourn v. State
92 S.W.3d 531 (Court of Criminal Appeals of Texas, 2002)
West v. State
124 S.W.3d 732 (Court of Appeals of Texas, 2003)
Fox v. State
115 S.W.3d 550 (Court of Appeals of Texas, 2002)
Potier v. State
68 S.W.3d 657 (Court of Criminal Appeals of Texas, 2002)
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928 S.W.2d 219 (Court of Appeals of Texas, 1996)
Easley v. State
986 S.W.2d 264 (Court of Appeals of Texas, 1998)
Philpot v. State
897 S.W.2d 848 (Court of Appeals of Texas, 1995)

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Carmouche, Monica Ann v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carmouche-monica-ann-v-state-texapp-2004.