Charles Lee Henderson, Jr. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 21, 2021
Docket01-20-00211-CR
StatusPublished

This text of Charles Lee Henderson, Jr. v. the State of Texas (Charles Lee Henderson, Jr. v. the State of Texas) 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
Charles Lee Henderson, Jr. v. the State of Texas, (Tex. Ct. App. 2021).

Opinion

Opinion issued December 21, 2021

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-20-00211-CR ——————————— CHARLES LEE HENDERSON, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 405th District Court Galveston County, Texas Trial Court Case No. 17-CR-1202

MEMORANDUM OPINION

In a single issue, Charles Lee Henderson contends the trial court erred in

failing to poll the jury about their possible exposure to a newspaper article about his

trial that was published on the day the jurors began deliberations. We affirm. BACKGROUND

A grand jury indicted Henderson for capital murder. In 2017, Henderson was

involved in a confrontation that turned fatal. Three men, Nathaniel Boykins, Harry

Zeno, and Anthony Sonnier drove in Boykins’s car to Abdul Thompson’s home,

where they found Thompson and Henderson standing outside. Boykins claimed that

Thompson owed him $200. For some reason, Sonnier, in the front passenger seat,

and Henderson started to argue. Boykins, in the driver’s seat, handed cash to Sonnier

to give to Henderson; Henderson saw Sonnier reaching for something and shot

Sonnier eleven times.

Henderson was tried in February 2020. The State presented its case over two

days; the defense did not present any evidence or witnesses and rested on the

afternoon of the second day of trial. That afternoon, before releasing the jury, the

trial court advised them: “Please remember my instructions that I’ve given you.

Don’t talk to anyone. I notice there was a newspaper reporter here in the courtroom

today. Y’all may have not noticed. Please refrain from doing any online research for

local news and try not to read the paper in the morning.”

The following morning, outside of the presence of the jury, the trial court

discussed with the attorneys for both sides an article that had appeared that morning

in the local newspaper, the Galveston Daily News. The newspaper article is not a

part of the record, but the trial court explained that it contained “a couple of

2 sentences” about an outstanding charge against Henderson that was unrelated to the

case and had not been discussed at trial. Henderson’s attorney noted that he had

searched other media but didn’t find coverage of the case in the Houston Chronicle

or any local TV stations, but he moved for a continuance “unless we could find out

from the jury whether or not they actually read the Daily News.” He agreed with the

trial court, however, that trying to find out whether the jury actually read the

newspaper article “would bring more attention to it.” He reiterated that, “[f]irst,

[he]’d ask for a motion to continue based upon one article in the Daily News.” The

attorney for the State opposed the motion for continuance, and the trial court denied

the motion, explaining that he had already instructed the jury “not to do any research,

read any news articles, Internet articles” related to the case and that the day before

he had again instructed the jury “not to pay any attention or read, specifically, local

news.” Unless a juror came forward to say that he or she had read the article or heard

another juror discussing the article, the trial court explained, the trial would proceed,

and he would not bring any further attention to the article. The jury was then brought

in, was read the court’s charge and their instructions, and heard closing arguments.

The jury returned a verdict of not guilty on the charge of capital murder, but guilty

on the lesser included offense of murder. Henderson was then sentenced to life

imprisonment.

3 DISCUSSION

Henderson contends he was denied a fair and impartial jury because the trial

court judge refused to poll the jury about whether they had read the Galveston Daily

News article.

Error was not preserved

The State contends Henderson failed to preserve for appellate review the issue

of polling the jurors because he never asked the trial court to poll the jurors about

the newspaper article. Henderson contends that his defense counsel raised the

complaint and timely asked to find out whether the jury had seen the newspaper

article, but the trial court refused. We conclude that error was not preserved.

Applicable Law

To preserve a complaint for appellate review under Texas Rule of Appellate

Procedure 33.1, the record must show that: (1) the complaining party made a timely

and specific request, objection, or motion; and (2) the trial court either ruled on the

request, objection, or motion or refused to rule and the complaining party objected

to that refusal. TEX. R. APP. P. 33.1(a); Geuder v. State, 115 S.W.3d 11, 13 (Tex.

Crim. App. 2003). A party’s failure to properly object can result in the forfeiture of

even a constitutional error. Clark v. State, 365 S.W.3d 333, 339 (Tex. Crim. App.

2012). While no “hyper-technical or formalistic use of words or phrases” is required

to preserve an error, the requesting party must still “let the trial judge know what he

4 wants, why he thinks himself entitled to it, and . . . do so clearly enough for the judge

to understand him at a time when the trial court is in a proper position to do

something about it.” Pena v. State, 285 S.W.3d 459, 464 (Tex. Crim. App. 2009);

Lankston v. State, 827 S.W.2d 907, 909 (Tex. Crim. App. 1992). A point of error on

appeal must comport with the complaint made at trial. See Pena, 285 S.W.3d at 464.

To make this determination, we consider the context in which the complaint was

made and the parties’ shared understanding at that time. Id.

Analysis

During the meeting to discuss the newspaper article outside the presence of

the jury, the trial court gave each attorney the opportunity “to make a record.”

Defense counsel stated:

I read the article; and the article did include certain extraneous offenses that were not entered into evidence during trial and would absolutely affect the minds of a juror if a juror were to read that before deliberation. I also searched in other media. The Houston Chronicle did not cover this case; and I don’t believe any of the TV stations, the local Houston TV stations, covered the cases. However, I’ve read case law that if media were to pop up in the middle of trial, widespread media, it would be incumbent upon the Defense to ask for a motion to continue. I think there’s just one article; but I think I have a duty to ask for a motion to continue based on that article, unless we could find out from the jury whether or not they actually read the Daily News. But again, as the Court talked about, that would bring more attention to it. Although they’ve been instructed not to read the press, there is always that possibility they could or they would. First, I’d ask for a motion to continue based upon one article in the Daily News. 5 The trial court then asked the State for its response, and the State opposed the motion

to continue. The trial court, noting the instructions he had already given the jury not

to pay attention to or read the local news, denied the motion to continue.

Here, defense counsel did not ask to poll the jury about whether they had seen

the newspaper article.

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

Related

Pena v. State
285 S.W.3d 459 (Court of Criminal Appeals of Texas, 2009)
Geuder v. State
115 S.W.3d 11 (Court of Criminal Appeals of Texas, 2003)
Mays v. State
318 S.W.3d 368 (Court of Criminal Appeals of Texas, 2010)
Lankston v. State
827 S.W.2d 907 (Court of Criminal Appeals of Texas, 1992)
Powell v. State
898 S.W.2d 821 (Court of Criminal Appeals of Texas, 1995)
Clark v. State
365 S.W.3d 333 (Court of Criminal Appeals of Texas, 2012)
Brian Walker Simon v. State
374 S.W.3d 550 (Court of Appeals of Texas, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Charles Lee Henderson, Jr. v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-lee-henderson-jr-v-the-state-of-texas-texapp-2021.