Cody Watson v. the State of Texas

Texas Court of Appeals, 10th District (Waco)·Decided January 29, 2026·No. 10-24-00363-CR·Published

Opinion

Court of Appeals

Tenth Appellate District of Texas

10-24-00363-CR

Cody Watson,

Appellant

v.

The State of Texas,

Appellee

On appeal from the

87th District Court of Freestone County, Texas Judge Amy Thomas Ward, presiding Trial Court Cause No. 23-065CR

JUSTICE SMITH delivered the opinion of the Court.

MEMORANDUM OPINION

Following a jury trial, Cody Watson was convicted of the offense of continuous sexual abuse of a child. See TEX. PENAL CODE ANN. § 21.02. The jury assessed his punishment at thirty years in prison. On appeal, Watson raises issues related to jury qualification, the trial court’s denial of his motion to quash the indictment, improper outcry witness testimony, and jury charge error. We affirm.

Jury Qualification

In his first issue, Watson argues that the trial court erred in failing to qualify the jury panel as required by article 35.12 of the Code of Criminal Procedure. See TEX. CODE CRIM. PROC. ANN. art. 35.12.

Article 35.12 requires the trial court, or someone under its direction, to ask prospective jurors whether they are qualified voters, whether they have been convicted of a theft or of a felony, and whether they are under indictment or legal accusation for a theft or a felony. Id. at (a). Watson specifically takes issue with the trial court’s alleged failure to ask whether the prospective jurors were convicted of, or under legal accusation for, a theft or felony.

Appellate courts must presume that the jury was properly impaneled and sworn unless the matter was disputed in the trial court or the record affirmatively shows the contrary. See TEX. R. APP. P. 44.2(c)(2). Watson acknowledges that he did not dispute juror qualification in the trial court. In fact, Watson’s trial counsel affirmatively voiced no objection to the venire members selected to serve on the jury. Citing generally to the voir dire volume of the reporter’s record, he claims the record “affirmatively shows” that the trial court failed to qualify the jury because the record does not document whether the procedure occurred. Article 35.12 does not require a record of compliance with its procedures. See TEX. CODE CRIM. PROC. ANN. art. 35.12.

Moreover, a silent record is not an affirmative showing that the statutory qualification procedure did not occur. See Osteen v. State, 642 S.W.2d 169, 171 (Tex. Crim. App. 1982). Watson has failed to overcome the Rule 44.2(c)(2) presumption that the jury was properly qualified.

Watson, however, urges us not to apply the Rule 44.2(c)(2) presumption.

He claims that the Court of Criminal Appeals exceeded its rulemaking authority in promulgating the rule because the presumption that the jury was properly qualified abridges and modifies a defendant’s substantive right to a fair trial. See TEX. GOV’T CODE ANN. § 22.108. Even if we refuse to apply the presumption as Watson requests, and we further assume that the trial court did not ask the article 35.12 qualifying questions, Watson’s first issue still fails for failure to demonstrate harm from this alleged error. Emphasizing the Sixth Amendment right to a trial by a fair jury, Watson contends that juror qualification in compliance with article 35.12 is constitutional error subject to harm analysis under Rule 44.2(a). See TEX. R. APP. P. 44.2(a). Watson does not identify – and we have not found – any controlling authority holding that a trial court's failure to ask the qualifying questions in article 35.12 is constitutional error rather than statutory error. In fact, “many – perhaps most – statutes are designed to help ensure the protection of one constitutional right or another. Having such a purpose does not convert a statutory right into a

one of federal constitutional dimension, much less a right whose violation is considered to be structural error.” Gray v. State, 159 S.W.3d 95, 97 (Tex. Crim. App. 2005). We reject Watson’s constitutional-error argument.

We must disregard any non-constitutional error that does not affect the appellant’s substantial rights. See TEX. R. APP. P. 44.2(b). To demonstrate harm from failure to qualify the jury, the record must show Watson was deprived of a lawfully constituted jury of qualified individuals. See Gray v. State, 233 S.W.3d 295, 298, 301 (Tex. Crim. App. 2007). Watson, claiming that this is an unworkable standard, does not identify any evidence that any jurors were unqualified due to being under legal accusation for, or convicted of, a theft or a felony. We have uncovered no such evidence in our own review of the record. Watson has thus failed to demonstrate harm.

Accordingly, we overrule Watson’s first issue.

Motion to Quash Indictment In his second issue, Watson claims that the trial court erred in denying his motion to quash the indictment. We disagree. STANDARD OF REVIEW When reviewing a trial court’s decision to deny a motion to quash an indictment, we apply a de novo standard of review. See Lawrence v. State, 240 S.W.3d 912, 915 (Tex. Crim. App. 2007).

ANALYSIS As relevant to the issue presented on appeal, the indictment alleged as follows:

… Cody Watson did then and there[,]

during a period that was 30 or more days in duration, to-wit: from on or about the 8th day of December, 2017 through the 8th day of December, 2022, when the defendant was 17 years of age or older, commit two or more acts of sexual abuse against a child younger than 14 years of age, namely,

with the intent to arouse or gratify the sexual desire of the defendant, engage in sexual contact with [A.A.], hereafter styled the complainant, by touching the genitals of the complainant, a child younger than 17 years of age

with the intent to arouse or gratify the sexual desire of the defendant, engage in sexual contact with [A.A.], hereafter styled the complainant, by touching the genitals of the complainant, a child younger than 17 years of age[.]

The day after the jury was empaneled and sworn, Watson filed his “Motion to Quash and Exception to Substance of the Indictment and Motion to Quash and Exception to Form of the Indictment.” Watson contended that the indictment failed to sufficiently inform him of the charge against him and did not “lay out if [sic] ‘plain and intelligible words’ an alleged criminal act.” The basis of his complaint was that the predicate offense paragraphs describe criminal acts against a victim under the age of seventeen, instead of a victim

under the age of fourteen as required for the offense of continuous sexual abuse of a child.

After hearing arguments of counsel, the trial court denied the motion to quash.

If a defendant does not object to a defect, error, or irregularity of form or substance in an indictment “before the date on which the trial on the merits commences,” he waives and forfeits the right to object to the defect, error, or irregularity and may not raise the objection on appeal or in any other post- conviction proceeding. TEX. CODE CRIM. PROC. ANN. art. 1.14(b). More specifically, the Court of Criminal Appeals has held that a defendant must object to any error in the indictment “before the day of trial and certainly before the jury is empaneled.” Jenkins v. State, 592 S.W.3d 894, 902 (Tex. Crim. App. 2018) (quoting Teal v. State, 230 S.W.3d 172, 178 n.24 (Tex. Crim. App. 2007)). However, we must determine whether the indictment is constitutionally sufficient before applying the waiver doctrine as set out in the statute. See Teal, 230 S.W.3d at 180-81. The question to be asked is: “Can the district court and the defendant determine, from the face of the indictment, that the indictment intends to charge a felony or other offense for which a district court has jurisdiction?” Id. at 181. If so, a defendant must make a pretrial objection to a defect in the indictment or forfeit the right to complain about it on appeal. Smith v. State, 309 S.W.3d 10, 18 (Tex. Crim. App. 2010).

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