Davis, Richard v. State

CourtCourt of Appeals of Texas
DecidedAugust 28, 2003
Docket14-02-00741-CR
StatusPublished

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

Opinion

Affirmed and Memorandum Opinion filed August 28, 2003

Affirmed and Memorandum Opinion filed August 28, 2003.

In The

Fourteenth Court of Appeals

____________

NO. 14-02-00741-CR

RICHARD DAVIS, Appellant

V.

THE STATE OF TEXAS, Appellee

_____________________________________________

On Appeal from the 182nd District Court

Harris County, Texas

Trial Court Cause No. 706,396

 

M E M O R A N D U M   O P I N I O N

Appellant Richard Davis challenges the trial court=s denial of his motion for post-conviction DNA testing.  We affirm.

I.  Factual and Procedural Background

Appellant was convicted of aggravated sexual assault of a child in 1996, after pleading nolo contendere in cause number 706,396 in the 182nd District Court of Harris County, Texas.  The trial court sentenced appellant to eight years’ confinement in the

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Texas Department of Criminal Justice, Institutional Division.  In December of 2001, appellant filed a pro se motion for post-conviction DNA testing in the trial court.  After the trial court appointed counsel, appellant filed a second motion for post-conviction DNA testing in February of 2002.  The trial court denied appellant=s motion for post-conviction DNA testing, and appellant now challenges that judgment.

II.  Issues Presented

Appellant presents the following issues for review:

(1)       Did the trial court violate appellant=s due process and confrontation rights under the Texas Constitution when it conducted a post-conviction DNA hearing in appellant=s absence?

(2)       Did the trial court violate appellant=s due process rights under the Texas Constitution by not holding an evidentiary hearing on his motion for post-conviction DNA testing?

(3)       Did the trial court reversibly err by denying appellant=s motion for DNA testing under article 64.03 of the Texas Code of Criminal Procedure?

III.  Analysis and Discussion

A.      Do the due course of law and confrontation provisions of the Texas Constitution require a defendant’s presence at a post-conviction DNA hearing?

In his first issue, appellant argues the trial court violated his confrontation clause and due process rights under the Texas Constitution by holding a post-conviction DNA hearing in his absence.  See Tex. Const. art. 1, '' 10, 19.  Appellant maintains that article 33.03 of the Texas Code of Criminal Procedure is dispositive of his first issue.  Article 33.03 is based on the Confrontation Clause and provides that a defendant must be personally present at trial in all felony prosecutions and in all misdemeanor prosecutions when the punishment may include a jail sentence.  See Tex. Code Crim. Proc. art. 33.03; Garcia v. State, 818 S.W.2d 756, 762B63 (Tex. Crim. App. 1991). 

By their plain language, the Texas Confrontation Clause and article 33.03 of the Code of Criminal Procedure apply to criminal prosecutions.  See Tex. Const. art. 1, ' 10;  Tex. Code Crim. Proc. art. 33.03.  Unlike a criminal prosecution, a post-conviction

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DNA hearing does not involve accusations against a criminal defendant.  Cravin v. State, 95 S.W.3d 506, 510 (Tex. App.CHouston [1st Dist.] 2002, pet. ref=d).  Accordingly, appellant does not have a constitutional right to Aconfront his accusers@ at a post-conviction DNA hearing because it is a proceeding appellant initiated himself.  Id.  Because it was not fundamentally unfair for the trial court to hold the post-conviction hearing in appellant=s absence when appellant was represented by counsel at the hearing, we find no violation of appellant=s due process rights.  See Cravin, 95 S.W.3d at 511.  For these reasons, we overrule appellant=s first issue.

B.      Did the trial court reversibly err by not holding an evidentiary hearing on appellant’s motion for post-conviction DNA testing?

In his second issue, appellant argues the trial court=s failure to conduct an evidentiary hearing with live witness testimony violated his due process rights under the Texas Constitution.[1]

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Rodriguez v. State
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Cravin v. State
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Ieppert v. State
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818 S.W.2d 756 (Court of Criminal Appeals of Texas, 1991)

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Davis, Richard v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davis-richard-v-state-texapp-2003.