David Sanchez v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 21, 2025
Docket13-24-00169-CR
StatusPublished

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Bluebook
David Sanchez v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

NUMBER 13-24-00169-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

DAVID SANCHEZ, Appellant,

v.

THE STATE OF TEXAS, Appellee.

ON APPEAL FROM THE 130TH DISTRICT COURT OF MATAGORDA COUNTY, TEXAS

MEMORANDUM OPINION

Before Chief Justice Tijerina and Justices West and Fonseca Memorandum Opinion by Justice Fonseca

Appellant David Sanchez was convicted of continuous sexual abuse of a young

child, a first-degree felony, and he was sentenced to thirty years’ imprisonment. See TEX.

PENAL CODE ANN. § 21.02(b). On appeal, he argues the trial court erred by: (1) “failing to

comply with rules governing jury communications” and “forcing the jury into marathon

deliberations”; and (2) issuing an improperly coercive Allen charge. We affirm. I. BACKGROUND

A Matagorda County grand jury returned an indictment alleging that, between

September 1, 2007, and May 1, 2008, Sanchez committed two or more acts of sexual

abuse against Diana,1 a child younger than fourteen years of age. See id.

At trial, Diana testified that she was born in 2002 and graduated from high school

in 2021. She attended pre-kindergarten in Bay City from August 2007 to May 2008. During

that time, her mother typically brought her to school, and she would take the bus to her

aunt Rachael’s trailer after school because her mother was at work. Rachael lived in the

trailer with Sanchez. According to Diana, Sanchez sexually abused her multiple times

during her pre-kindergarten year after the bus dropped her off. Specifically, he licked her

genital area, forced her to touch his penis, and penetrated her vagina with his hand. She

stated that the abuse occurred “almost every week or every other week.”

Diana said that she told her friend Torri about the abuse when she was twelve

years old, but she asked Torri not to tell anyone. Diana later reported the abuse to her

mother in 2018, when she was a freshman in high school. She explained that she delayed

telling her mother because she was afraid that it would upset her and make her feel guilty.

Diana’s mother contacted police, and Diana submitted to a sexual assault examination

and a forensic interview. The nurse examiner and forensic interviewer testified at trial as

to Diana’s recollections of the abuse, which were consistent with her trial testimony.

Following the close of evidence at the guilt-innocence phase of trial on March 28,

2024, the jury was excused to deliberate at 1:41 p.m. The clerk’s record contains eleven

1 We use a pseudonym to protect the complainant’s identity. See TEX. CONST. art. I, § 30(a)(1)

(providing that a crime victim has “the right to be treated . . . with respect for the victim’s dignity and privacy throughout the criminal justice process”); TEX. CODE CRIM. PROC. ANN. ch. 58, subch. C (“Confidentiality of Identifying Information of Sex Offense Victims”).

2 jury notes delivered to the trial court between 3:00 p.m. to 8:55 p.m. One note, delivered

at 5:07 p.m., asked “[w]hat do we do if we are at an [i]mpass[e]?” The final note, delivered

at 8:55 p.m., stated “[w]e are at an [i]mpass[e] and we are still deadlocked without a

unanimous decision.” The trial court then issued a supplemental charge instructing the

jury to continue its deliberations. Subsequently, the jury returned a unanimous guilty

verdict at 10:35 p.m.

The jury sentenced Sanchez as set forth above, and the trial court rendered

judgment in accordance with the jury’s findings. This appeal followed.

II. DISCUSSION

A. Jury Communications and Deliberations

By a multifarious first issue, Sanchez contends that the trial court committed

reversible error by “failing to comply with rules governing jury communications” and

“forcing the jury into marathon deliberations.”

Article 36.27 of the Texas Code of Criminal Procedure states:

When the jury wishes to communicate with the court, it shall so notify the sheriff, who shall inform the court thereof. Any communication relative to the cause must be written, prepared by the foreman and shall be submitted to the court through the bailiff. The court shall answer any such communication in writing, and before giving such answer to the jury shall use reasonable diligence to secure the presence of the defendant and his counsel, and shall first submit the question and also submit his answer to the same to the defendant or his counsel [f]or objections and exceptions, in the same manner as any other written instructions are submitted to such counsel, before the court gives such answer to the jury, but if he is unable to secure the presence of the defendant and his counsel, then he shall proceed to answer the same as he deems proper. The written instruction or answer to the communication shall be read in open court unless expressly waived by the defendant.

All such proceedings in felony cases shall be a part of the record and recorded by the court reporter.

TEX. CODE CRIM. PROC. ANN. art. 36.27.

3 In this case, although the clerk’s record contains eleven different jury notes, the

reporter’s record indicates that only three of the notes were discussed in open court.

Sanchez argues that this violated the statute and deprived him of his constitutional right

to a fair trial. He observes that one of the jury notes asks what to do “if we are at an

[i]mpass[e]”; the trial court replied by instructing the jury to “continue your deliberations,”

but because the note was not discussed on the record, there is no indication that defense

counsel had a “chance to respond” to the note. Moreover, another of the undiscussed jury

notes was a request to “take a break” at 7:11 p.m., and though the trial court granted that

request, it is unclear how long the break was or whether defense counsel was made

aware of the request.

The State contends that there is no error apparent from the record because,

although it does not affirmatively show the trial court complied with article 36.27 as to the

undiscussed notes, it also does not show it failed to comply. See Green v. State, 912

S.W.2d 189, 192 (Tex. Crim. App. 1995) (“In the absence of a showing to the contrary in

the record, we presume the trial court’s response [to a jury note] was in open court and

in appellant’s presence. . . . Therefore, we also presume appellant had an opportunity to

object.”); see also Word v. State, 206 S.W.3d 646, 651 (Tex. Crim. App. 2006) (holding

that appellant “procedurally defaulted any claimed violation of Article 36.27 and any

objection to the trial court’s answers to the jury questions” because “the record . . . did not

show that the trial court failed to notify appellant of the jury questions or that appellant

objected to the trial court’s answers to the jury questions”).

The State also contends that, even if the court violated the statute by failing to read

its answers to certain jury notes in open court, Sanchez has not demonstrated he suffered

4 harm resulting from that failure. See TEX. R. APP. P. 44.2(b) (providing that non-

constitutional error must be disregarded unless it affects substantial rights).

We agree. Sanchez argues, without reference to authority, that “[t]he trial court’s

unrecorded communication with the jury begins to put inappropriate pressure on them to

reach a decision before being released.” However, the trial court never gave the jury any

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