Craig, Richard Latood v. State

CourtCourt of Appeals of Texas
DecidedJune 26, 2003
Docket14-00-01282-CR
StatusPublished

This text of Craig, Richard Latood v. State (Craig, Richard Latood 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
Craig, Richard Latood v. State, (Tex. Ct. App. 2003).

Opinion

Affirmed and Memorandum Opinion filed June 26, 2003

Affirmed and Memorandum Opinion filed June 26, 2003.

In The

Fourteenth Court of Appeals

____________

NO. 14-00-01282-CR

RICHARD LATOOD CRAIG, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 183rd District Court

Harris County, Texas

Trial Court Cause No. 836,874

M E M O R A N D U M   O P I N I O N

Appellant was convicted by a jury for forgery and sentenced to two years= confinement in the Texas Department of Criminal Justice, Institutional Division.  On appeal, appellant complains in one issue that allowing the State to impeach a defense witness regarding his prior convictions was error.  We affirm the trial court=s judgment.

FACTUAL AND PROCEDURAL BACKGROUND


Appellant devised a plan involving the passing of forged checks using fake identifi-cation.  His accomplice, LaShonda Henderson, would present the checks and split the proceeds with appellant.  Eventually, both Henderson and appellant were arrested for forgery by attempting to use bad checks at a department store.

At trial, appellant=s girlfriend, Valencia Johnson, who was with appellant at the department storeCbut unaware of the schemeCtestified.  She said she overheard appellant tell Henderson “[b]uy whatever you want to buy.  It’s your money.”  The trial court then allowed the State to impeach the appellant through Johnson, specifically asking Johnson whether she knew of his four prior forgery convictions.  Johnson denied knowledge of each prior forgery.  Appellant was then found guilty of one count of felony forgery.  Appellant appealed.

STANDARD OF REVIEW

We review a trial court’s evidentiary ruling under an abuse of discretion standard.  Guzman v. State, 955 S.W.2d 85, 89 (Tex. Crim. App. 1997).  A trial court must be given wide latitude to admit or exclude evidence as it sees fit.  Theus v. State, 845 S.W.2d 874, 881 (Tex. Crim. App. 1992).  As long as the trial court=s ruling was within the zone of reasonable disagreement, an appellant court may not disturb it.  Montgomery v. State, 810 S.W.2d 372, 391 (Tex. Crim. App. 1990).

DISCUSSION

In appellant=s only issue, he complains it was error to allow the State to impeach him by introduction of his prior convictions through a defense witness.  The State defended its position by citing to Texas Rules of Evidence 806.  That Rule states in part the following:

When a hearsay statement, or a statement defined in Rule 801(e)(2)(C), (D), or (E) . . . has been admitted in evidence, the credibility of the declarant may be attacked, and if attacked may be supported by any evidence which would be admissible for those purposes if declarant had testified as a witness.


Tex. R. Evid. 806.  The intent of Rule 806 is to “permit impeachment and rehabilitation by any means that could be used if the declarant were a witness.”  Bee v. State, 974 S.W.2d 184, 190 (Tex. App.CSan Antonio 1998, no pet.).

The purpose of Rule 806 is “to establish a standard for attacking the credibility of a hearsay declarant.”  United States v. Graham, 858 F.2d 986, 990 (5th Cir. 1988).[1]  When appellant=s counsel allowed Johnson to testify to hearsay statements, counsel put appellant=s credibility at issue, see United States v. Lawson, 608 F.2d 1129, 1129 (6th Cir. 1979), just as if appellant had taken the stand.  See id.  Rule 806 can “set a trap for criminal defense counsel.  A defendant who chooses not to testify but who succeeds in getting his or her own exculpatory statements into evidence runs the risk of having those statements impeached by felony convictions.”  United States v. Montana, 19 F.Supp.2d 873, 876 (N.D. Ill. 1998) (citing Jack Weinstein & Margaret Berger, Weinstein=s Federal Evidence ' 806.04[2][b], at 806B1 to 806B12 (Joseph McLaughlin ed., 2d ed. 1998)).  The general reason for this rule is to prevent one side from trying a case based largely on hearsay statements, and then objecting when the other side attempts to impeach the declarant of the hearsay statements.  See Marcel v. State, 64 S.W.3d 677, 679 (Tex. App.CHouston [1st Dist.] 2001, pet. denied).

A.        Rule 806

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

Related

United States v. Charles William Lawson
608 F.2d 1129 (Sixth Circuit, 1979)
United States v. Arch Emmett Graham
858 F.2d 986 (Fifth Circuit, 1988)
Pierre v. State
2 S.W.3d 439 (Court of Appeals of Texas, 1999)
Appling v. State
904 S.W.2d 912 (Court of Appeals of Texas, 1995)
Wilson v. State
71 S.W.3d 346 (Court of Criminal Appeals of Texas, 2002)
Colvin v. State
54 S.W.3d 82 (Court of Appeals of Texas, 2001)
Griffith v. State
983 S.W.2d 282 (Court of Criminal Appeals of Texas, 1998)
White v. State
21 S.W.3d 642 (Court of Appeals of Texas, 2000)
Marcel v. State
64 S.W.3d 677 (Court of Appeals of Texas, 2001)
Bee v. State
974 S.W.2d 184 (Court of Appeals of Texas, 1998)
Bryant v. State
997 S.W.2d 673 (Court of Appeals of Texas, 1999)
Rojas v. State
986 S.W.2d 241 (Court of Criminal Appeals of Texas, 1998)
Theus v. State
845 S.W.2d 874 (Court of Criminal Appeals of Texas, 1992)
Montgomery v. State
810 S.W.2d 372 (Court of Criminal Appeals of Texas, 1991)
Guzman v. State
955 S.W.2d 85 (Court of Criminal Appeals of Texas, 1997)
United States v. Montana
19 F. Supp. 2d 873 (N.D. Illinois, 1998)
Mitchell's Adm'x v. Harlan Central C. Co.
93 S.W.2d 347 (Court of Appeals of Kentucky (pre-1976), 1936)

Cite This Page — Counsel Stack

Bluebook (online)
Craig, Richard Latood v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-richard-latood-v-state-texapp-2003.