Chuck Allen Little v. State

CourtCourt of Appeals of Texas
DecidedOctober 10, 2013
Docket02-12-00086-CR
StatusPublished

This text of Chuck Allen Little v. State (Chuck Allen Little 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
Chuck Allen Little v. State, (Tex. Ct. App. 2013).

Opinion

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

NO. 02-12-00086-CR

CHUCK ALLEN LITTLE APPELLANT

V.

THE STATE OF TEXAS STATE

----------

FROM THE 415TH DISTRICT COURT OF PARKER COUNTY

MEMORANDUM OPINION1

I. INTRODUCTION

Appellant Chuck Allen Little appeals his convictions for kidnapping and

burglary of a habitation. In four issues, Little argues that the trial court abused its

discretion by not empanelling a jury to determine his competency to stand trial;

that the trial court committed reversible error by ordering expert evaluation

regarding his competency to stand trial without being afforded his right to 1 See Tex. R. App. P. 47.4. counsel; that his appointed trial counsel failed to request a hearing regarding his

desire for self-representation; and that the trial court erred by denying his request

for hybrid representation. We will affirm.

II. BACKGROUND

Upset that his girlfriend had ended their relationship, Little held a knife to

her and threatened to kill her if she did not accompany him from Parker County

to either Oklahoma or Mexico. The girlfriend temporarily escaped the house they

were in, and a neighbor called the police and reported that Little had dragged her

back into the house. Little released her to police when they arrived but escaped

out the back and was later apprehended.

The State indicted Little for kidnapping and assault on May 5, 2011. For

reasons that are not apparent from the record, on June 1, 2011, the trial court

ordered that Little undergo an expert evaluation to determine whether he was

competent to stand trial. Over the next six weeks, Little filed numerous pro se

documents, including affidavits of indigency, letters to the trial court expressing

his desire to represent himself, and motions to dismiss the charges against him.

Some of the motions that Little filed in the trial court include a request for legal

supplies, a request for funds to retain a legal assistant, and a motion requesting

that the State pay for a private investigator.

On July 15, 2011, Dr. Peter Oropeza conducted a competency evaluation

and determined that Little was competent to stand trial. Four days later, the trial

court appointed Matt McConahay to serve as Little‘s trial counsel. Despite the

2 appointment of trial counsel, Little continued to send the trial court numerous

motions and demands. One of the documents is a letter in which Little

expressed his desire to fire McConahay. On December 1 and on December 5,

2011, the clerk‘s record reflects that the trial court again ordered that Little be

examined by an expert to determine whether he was competent to stand trial.

On December 8, 2011, the trial court ―unilaterally‖ held a hearing ―to cover

pretrial matters.‖ At the December 8 hearing, Little requested that he be allowed

―a hybrid counsel to help assist [him]‖ but added that he ―would like to maintain

control of the case.‖ Little specifically said that he did not want the assistance of

appointed counsel McConahay. The trial court denied Little‘s request for hybrid

counsel. After further discussion, the trial court gave Little the choice between

allowing McConahay to continue as appointed counsel, allowing McConahay to

serve as standby counsel, or allowing Little to represent himself without the aid of

counsel at all. Little stated that he desired ―standby counsel.‖ After admonishing

Little regarding the possible perils of self-representation, the trial court granted

Little‘s request for self-representation with standby counsel. On December 12,

2011, the trial court, finding Little competent to stand trial, ordered that the

previous orders for additional expert evaluations be set aside. Specifically, the

trial court stated that after ―having examined [Little] in open court and after having

received [Little‘s] writings . . . there [was] not a current issue as to [Little‘s]

competency to stand trial.‖ The trial court further stated that it had considered a

previous determination of competency to stand trial in making this finding. The

3 next day, the trial court again held a hearing in which the trial court delivered to

Little its order setting aside the previous orders for an additional competency

evaluation and its findings regarding Little‘s competency to stand trial. Little,

accompanied by standby counsel, did not object. On December 19, 2011, the

State filed a superseding indictment adding the charge of burglary of a habitation.

A jury found Little guilty of kidnapping and burglary of a habitation and

assessed punishment at ninety-nine years‘ incarceration for kidnapping and fifty

years‘ incarceration for burglary of a habitation with the sentences to run

concurrently. Standby counsel filed a motion for new trial and arrest of judgment,

which the trial court overruled. After Little filed an affidavit of indigency seeking

appointed appellate counsel, the trial court appointed appellate counsel. This

appeal followed.

III. DISCUSSION

A. Little’s Competency to Stand Trial

In part of his first issue, Little contends that the trial court abused its

discretion ―when it found [him] competent to stand trial.‖ Specifically, Little

argues that the trial court erred by not assembling a jury to determine whether he

was competent to stand trial. He argues that the trial court should have

conducted a jury trial on the issue because evidence raised a bona fide doubt

that he was not competent. In his argument, Little also suggests that ―at the very

minimum, a hearing should have been held‖ to assess his competency. We

conclude that the trial court did conduct an informal inquiry under the proper

4 statutory scheme and that the trial court did not abuse its discretion by declaring

Little competent to stand trial.

The conviction of an accused person while he is legally incompetent to

stand trial violates due process. See McDaniel v. State, 98 S.W.3d 704, 709

(Tex. Crim. App. 2003). A defendant is incompetent to stand trial if he does not

have a ―(1) sufficient present ability to consult with [his] lawyer with a reasonable

degree of rational understanding; or (2) a rational as well as factual

understanding of the proceedings against [him].‖ Tex. Code Crim. Proc. Ann. art.

46B.003(a) (West 2006). A defendant is presumed to be competent to stand

trial, and incompetence must be established by a preponderance of the

evidence. Id. art. 46B.003(b).

The standard of review is whether the trial court abused its discretion by

failing to empanel a jury for the purpose of conducting a competency hearing.

Moore v. State, 999 S.W.2d 385, 393 (Tex. Crim. App. 1999), cert. denied, 530

U.S. 1216 (2000); Lawrence v. State, 169 S.W.3d 319, 322 (Tex. App.—Fort

Worth 2005, pet. ref‘d). We do not substitute our own judgment for that of the

trial court; rather, we consider the totality of the facts surrounding the trial court‘s

decision to determine whether the trial court acted arbitrarily or unreasonably.

Montoya v. State,

Related

Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Satterwhite v. Texas
486 U.S. 249 (Supreme Court, 1988)
Lawrence v. State
169 S.W.3d 319 (Court of Appeals of Texas, 2005)
Word v. State
206 S.W.3d 646 (Court of Criminal Appeals of Texas, 2006)
Conrad v. State
10 S.W.3d 43 (Court of Appeals of Texas, 1999)
Amador v. State
221 S.W.3d 666 (Court of Criminal Appeals of Texas, 2007)
Gray v. State
257 S.W.3d 825 (Court of Appeals of Texas, 2008)
Montoya v. State
291 S.W.3d 420 (Court of Criminal Appeals of Texas, 2009)
Patrick v. State
906 S.W.2d 481 (Court of Criminal Appeals of Texas, 1995)
Moore v. State
999 S.W.2d 385 (Court of Criminal Appeals of Texas, 1999)
Sossamon v. State
110 S.W.3d 57 (Court of Appeals of Texas, 2002)
Collier v. State
959 S.W.2d 621 (Court of Criminal Appeals of Texas, 1997)
Hanson v. State
11 S.W.3d 285 (Court of Appeals of Texas, 2000)
Robinson v. State
240 S.W.3d 919 (Court of Criminal Appeals of Texas, 2007)
Barrios v. State
27 S.W.3d 313 (Court of Appeals of Texas, 2000)
Newman v. State
331 S.W.3d 447 (Court of Criminal Appeals of Texas, 2011)
Cudjo v. State
345 S.W.3d 177 (Court of Appeals of Texas, 2011)
McDaniel v. State
98 S.W.3d 704 (Court of Criminal Appeals of Texas, 2003)

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