Dennis Lee Giddings v. the State of Texas

CourtTexas Court of Appeals, 4th District (San Antonio)
DecidedJune 24, 2026
Docket04-25-00487-CR
StatusPublished

This text of Dennis Lee Giddings v. the State of Texas (Dennis Lee Giddings v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 4th District (San Antonio) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dennis Lee Giddings v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-25-00487-CR

Dennis Lee GIDDINGS, Appellant

v.

The STATE of Texas, Appellee

From the 451st Judicial District Court, Kendall County, Texas Trial Court No. 9787 Honorable Kirsten Cohoon, Judge Presiding

Opinion by: Lori I. Valenzuela, Justice

Sitting: Irene Rios, Justice Lori I. Valenzuela, Justice Velia J. Meza, Justice

Delivered and Filed: June 24, 2026

AFFIRMED

In three issues, appellant Dennis Lee Giddings challenges his conviction for driving while

intoxicated, third offense or more. We overrule Giddings’s appellate issues and affirm the

judgment of conviction.

BACKGROUND

On July 4, 2024, Giddings was involved in an automobile collision with a City of Boerne

firetruck. Giddings maintained that the firetruck hit him, while the truck’s driver testified that 04-25-00487-CR

Giddings entered his lane and collided with the back of the truck. The police officers who

responded to the collision believed Giddings was intoxicated, and they arrested him. A Kendall

County grand jury indicted him for driving while intoxicated, third or more.

After hearing the evidence presented at trial, the jury found Giddings guilty as charged.

The jury also found the State’s allegations that Giddings had two prior felony convictions to be

true, and it assessed his punishment at 50 years’ confinement. The trial court subsequently signed

a judgment of conviction that was consistent with the jury’s verdict. Giddings now appeals.

ANALYSIS

Alleged Discovery Violation

In his first issue, Giddings argues the State violated its discovery obligations regarding

testimony from Matthew Gregory, the firefighter and EMT who was driving the firetruck and who

tried to assess Giddings at the scene. Giddings contends that the State had an obligation to disclose

that Gregory’s trial testimony would include details not recited in his written EMT report.

Standard of Review and Applicable Law

We review a trial court’s rulings on pretrial discovery matters and its evidentiary rulings

under an abuse of discretion standard. State v. Heath, 696 S.W.3d 677, 688 (Tex. Crim. App.

2024); Sopko v. State, 637 S.W.3d 252, 256 (Tex. App.—Fort Worth 2021, no pet.). A trial court

does not abuse its discretion if its ruling is within the zone of reasonable disagreement. Heath, 696

S.W.3d at 688–89. Under this standard, we may not substitute our judgment for the trial court’s.

Id. at 689.

Article 39.14 of the Texas Code of Criminal Procedure, also known as the Michael Morton

Act, provides:

as soon as practicable after receiving a timely request from the defendant the state shall produce and permit the inspection and the electronic duplication, copying, and

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photographing, by or on behalf of the defendant, of any offense reports, any designated documents, papers, written or recorded statements of the defendant or a witness, including witness statements of law enforcement officers but not including the work product of counsel for the state in the case and their investigators and their notes or report, or any designated books, accounts, letters, photographs, or objects or other tangible things not otherwise privileged that constitute or contain evidence material to any matter involved in the action and that are in the possession, custody, or control of the state or any person under contract with the state.

TEX. CODE CRIM. PROC. art. 39.14(a). As used in Article 39.14, material “means having a logical

connection to a consequential fact and is synonymous with relevant[.]” Watkins v. State, 619

S.W.3d 265, 290 (Tex. Crim. App. 2021) (internal quotation marks omitted). Article 39.14 thus

grants criminal defendants “a general statutory right to discovery . . . beyond the guarantees of due

process.” Id. at 291.

Application

On appeal, Giddings argues the State violated its discovery obligations under the Fifth and

Fourteenth Amendments of the United States Constitution, Brady v. Maryland, 1 and Article 39.14.

At trial, however, Giddings asserted only an Article 39.14 objection to Gregory’s testimony. He

therefore did not preserve his Fifth and Fourteenth Amendment or Brady complaints for our

review. See TEX. R. APP. P. 33.1(a)(1); Keeter v. State, 175 S.W.3d 756, 761 (Tex. Crim. App.

2005).

In his Article 39.14 complaints, Giddings does not argue that the State failed to disclose

Gregory’s written report or his identity as a testifying witness. Rather, he complains that Gregory

testified to details not contained in the written report the State disclosed to Giddings.

Gregory testified without objection that after the collision, he noticed that Giddings’s

vehicle came to rest “a substantial distance,” which he estimated to be 1,180 feet, away from the

1 373 U.S. 83 (1963).

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firetruck and the collision site. He explained that the distance between the two vehicles led him to

believe “[t]hat there was a high rate of speed involved from [Giddings’s] vehicle to have slid that

far or there was just complete lack of control of the vehicle.” He further testified that as he was

trying to assess Giddings’s physical condition after the collision, Giddings swore at him, ignored

his instructions to stay seated until further assistance arrived, and “swatted [his hand] away” when

he tried to help Giddings out of his crashed vehicle. Gregory also testified that he noticed “a strong

smell of alcohol coming from the vehicle.”

At that point, Giddings objected to Gregory’s testimony:

Objection, Your Honor. We have a report in this case. We don’t have any information related to the testimony that’s there now. . . . It’s a Michael Morton violation. We don’t have any evidence related to this.

Giddings confirmed that his objection was limited to the testimony described above and Gregory’s

statements that he estimated Giddings’s vehicle came to rest approximately 1,180 feet past the

collision site.

During a conference outside the jury’s presence, the State initially represented, “The

majority of the testimony that’s coming out are things that I’m hearing for the first time.” Giddings

responded, “[W]e are of the position that [the State] knew what the answers to these questions

were, knew that that was going to be part of this. They surely rehearsed that. And none of that

information was made available to us before this moment.”

As the conference continued, the State read portions of Gregory’s report into the record:

It took a minute to get down to the other vehicle involved. Once there I found a 50- to 60-year-old male sitting in his car. I had introduced myself and asked if he was okay or if he was hurt. His immediate response was to begin cursing me out and accusing me of hitting him. I again asked him if he was okay or if he was hurt. He again responded with profanity and accusing me of swerving into his lane and hitting him. I advised him law enforcement would determine who’s at fault and that all I cared about was that he was okay. I persisted to inquire if he was hurt with no

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success. During this exchange, I could smell a very strong odor of alcohol coming from the vehicle.

After the State read Gregory’s report into the record, the trial court then overruled Giddings’s

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Georgia R. Freitag
230 F.3d 1019 (Seventh Circuit, 2000)
Keeter v. State
175 S.W.3d 756 (Court of Criminal Appeals of Texas, 2005)
Menard v. State
193 S.W.3d 55 (Court of Appeals of Texas, 2006)
Ocon v. State
284 S.W.3d 880 (Court of Criminal Appeals of Texas, 2009)
White v. State
225 S.W.3d 571 (Court of Criminal Appeals of Texas, 2007)
Thieleman v. State
187 S.W.3d 455 (Court of Criminal Appeals of Texas, 2005)
Thomas v. State
336 S.W.3d 703 (Court of Appeals of Texas, 2011)
Barnett v. State
161 S.W.3d 128 (Court of Appeals of Texas, 2005)
McQuarrie v. State
380 S.W.3d 145 (Court of Criminal Appeals of Texas, 2012)
Ferrer v. State
548 S.W.3d 115 (Court of Appeals of Texas, 2018)

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