Chad Anthony Splawn v. State

CourtCourt of Appeals of Texas
DecidedFebruary 1, 2005
Docket06-03-00243-CR
StatusPublished

This text of Chad Anthony Splawn v. State (Chad Anthony Splawn 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
Chad Anthony Splawn v. State, (Tex. Ct. App. 2005).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana


______________________________


No. 06-03-00243-CR



CHAD ANTHONY SPLAWN, Appellant

V.

THE STATE OF TEXAS, Appellee




On Appeal from the 6th Judicial District Court

Lamar County, Texas

Trial Court No. 19325





Before Morriss, C.J., Ross and Carter, JJ.

Opinion by Chief Justice Morriss



O P I N I O N


            Life imprisonment, on each of the two charges of aggravated sexual assault of a child and indecency with a child, resulted from Chad Anthony Splawn's single jury trial. None of Splawn's ten points of error attacks the sufficiency of the evidence, so we discuss the evidence only as necessary to address the points Splawn raises.

            We affirm Splawn's conviction on both charges, affirm the mandatory life sentence on the aggravated sexual assault of a child conviction, and reverse his life sentence on the indecency with a child conviction, remanding the indecency sentence to the trial court for a new hearing on punishment. We reach that result because we hold that (A) the jury charge on range of punishment contained egregiously harmful error and thus requires a new punishment hearing; but (B) denying Splawn's motion for continuance was discretionary, (C) the State's notice regarding extraneous offenses was timely and adequate, (D) the location of the trial was proper, (E) the State's notice of enhancements  was  sufficient,  (F)  the  State  was  not  required  to  disclose  Splawn's  oral statements,  (G)  denying  Splawn's  challenges  of  venirepersons  for  cause  was  not  error,  and (H) denying Splawn's Batson challenges was not error.

A. Jury Charge on Range of Punishment Contained Egregiously Harmful Error

            In his first two points of error, Splawn contends (1) that the jury charge contained a harmfully erroneous range of punishment for the indecency with a child conviction and (2) that denying his motion for new trial asserting that error was, itself, error. Although the State argued at trial that Splawn's punishment on the indecency conviction was properly enhanced under Tex. Pen. Code Ann. § 12.42(b) (Vernon Supp. 2004–2005), the State now concedes this was incorrect because the previous offense was not a final conviction, but had instead been subject to community supervision. The jury was thus erroneously charged that the range of punishment for the indecency conviction was five to ninety-nine years or life.

            The trial objection made to this portion of the charge is focused on a claim of a lack of notice of the State's proposed enhancements and does not address the range of punishment error. Because Splawn did not object to the range-of-punishment error, the error is reversible only if it caused him egregious harm. See Cartwright v. State, 833 S.W.2d 134, 137 (Tex. Crim. App. 1992) (applying Almanza analysis to error in charging range of punishment); see also Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985). In determining whether egregious harm occurred, we review the error in light of the entire jury charge, the state of the evidence, including the contested issues and the weight of probative evidence, the argument of counsel, and all other relevant evidence revealed by the record as a whole. Skinner v. State, 956 S.W.2d 532, 544 (Tex. Crim. App. 1997) (quoting Almanza, 686 S.W.2d at 171)).

            Errors resulting in egregious harm are those that affect the very basis of the case, deprive the defendant of a valuable right, or vitally affect a defensive theory. Hutch v. State, 922 S.W.2d 166, 171 (Tex. Crim. App. 1996) (citing Almanza, 686 S.W.2d at 171); Washington v. State, 59 S.W.3d 260, 265 (Tex. App.—Texarkana 2001, pet. ref'd).

            In this case, the harm is obvious: Splawn was sentenced to life in prison for a charge on which he could properly have been sentenced to a maximum of only twenty years.

            The State has suggested that we have the authority to reform the sentence from the maximum under the erroneous range to the maximum under the correct, lesser range, arguing this would obviously satisfy the intention of the jury. The general rule is that, if we have "the necessary data and evidence before [the court] for reformation, the judgment and sentence may be reformed on appeal." Banks v. State, 708 S.W.2d 460 (Tex. Crim. App. 1986). The State directs us to an unpublished case in which the court, without comment or analysis, reformed a maximum sentence under an incorrect range to the maximum sentence under the lesser range. See Crain v. State, No. 14-97-00234-CR, 1998 Tex. App. LEXIS 4478 (Tex. App.—Houston [14th Dist.] July 23, 1998, no pet.) (not designated for publication). Crain relied on McCray v. State, 876 S.W.2d 214, 217 (Tex. App.—Beaumont 1994, no pet.), as authority. In McCray, the court, in a split opinion, concluded with little analysis that, because the trial court had sentenced McCray to the highest level available under the wrong range of punishment, it could reform that sentence to the highest level under the lower range.

            Other courts have declined to apply that theory, and have reversed cases where a fact-finder was provided with the wrong range of punishment and remanded the case to the trial court for a new punishment hearing. See Bailey v. State, 7 S.W.3d 721, 725 (Tex. App.—Corpus Christi 1999), vacated on other grounds, 38 S.W.3d 157 (Tex. Crim. App. 2001); State v. Rowan, 927 S.W.2d 116 (Tex. App.—Houston [1st Dist.] 1996, no pet.).

            We conclude sentence reformation is not appropriate here. In each of the cases allowing reformation, only a single charge had been prosecuted. While we find reformation attractive when there is a single charge—if a fact-finder found the maximum punishment to be the right one under a high level felony, it would certainly find the maximum punishment proper under a lesser charge—it is problematic here.

            This case is more complex because two different charges were involved, and the error may well have influenced the jury's assessment of punishment on the indecency charge. The erroneous range of punishment charged on the indecency conviction was communicated to the jury at the same time as the accurate charge concerning the mandatory life sentence for the enhanced assault conviction. The jury was charged that the indecency conviction was punishable with as much as a life sentence, the mandatory sentence on the other enhanced conviction.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Batson v. Kentucky
476 U.S. 79 (Supreme Court, 1986)
Hernandez v. New York
500 U.S. 352 (Supreme Court, 1991)
Washington v. State
59 S.W.3d 260 (Court of Appeals of Texas, 2001)
King v. State
29 S.W.3d 556 (Court of Criminal Appeals of Texas, 2000)
Flores v. State
888 S.W.2d 187 (Court of Appeals of Texas, 1994)
Cole v. State
987 S.W.2d 893 (Court of Appeals of Texas, 1998)
Hayden v. State
66 S.W.3d 269 (Court of Criminal Appeals of Texas, 2001)
Guzman v. State
85 S.W.3d 242 (Court of Criminal Appeals of Texas, 2002)
Jasper v. State
61 S.W.3d 413 (Court of Criminal Appeals of Texas, 2001)
Sells v. State
121 S.W.3d 748 (Court of Criminal Appeals of Texas, 2003)
Skinner v. State
956 S.W.2d 532 (Court of Criminal Appeals of Texas, 1997)
Feldman v. State
71 S.W.3d 738 (Court of Criminal Appeals of Texas, 2002)
Fairrow v. State
112 S.W.3d 288 (Court of Appeals of Texas, 2003)
State v. Rowan
927 S.W.2d 116 (Court of Appeals of Texas, 1996)
Murphy v. State
112 S.W.3d 592 (Court of Criminal Appeals of Texas, 2003)
Nance v. State
946 S.W.2d 490 (Court of Appeals of Texas, 1997)
Heiselbetz v. State
906 S.W.2d 500 (Court of Criminal Appeals of Texas, 1995)
Self v. State
860 S.W.2d 261 (Court of Appeals of Texas, 1993)
Janecka v. State
937 S.W.2d 456 (Court of Criminal Appeals of Texas, 1996)
Banks v. State
708 S.W.2d 460 (Court of Criminal Appeals of Texas, 1986)

Cite This Page — Counsel Stack

Bluebook (online)
Chad Anthony Splawn v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chad-anthony-splawn-v-state-texapp-2005.