Cody Watson v. the State of Texas

CourtTexas Court of Appeals, 10th District (Waco)
DecidedJanuary 29, 2026
Docket10-24-00363-CR
StatusPublished

This text of Cody Watson v. the State of Texas (Cody Watson v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 10th District (Waco) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cody Watson v. the State of Texas, (Tex. Ct. App. 2026).

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.

Cody Watson v. The State of Texas Page 2 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

Cody Watson v. The State of Texas Page 3 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).

Cody Watson v. The State of Texas Page 4 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

Cody Watson v. The State of Texas Page 5 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

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