Eric Renee Munoz v. State

CourtCourt of Appeals of Texas
DecidedJanuary 29, 2009
Docket01-08-00223-CR
StatusPublished

This text of Eric Renee Munoz v. State (Eric Renee Munoz 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
Eric Renee Munoz v. State, (Tex. Ct. App. 2009).

Opinion

Opinion issued January 29, 2009





In The

Court of Appeals

For The

First District of Texas



NO. 01-08-00223-CR



ERIC RENEE MUNOZ, Appellant



V.



THE STATE OF TEXAS, Appellee



On Appeal from the 351st District Court

Harris County, Texas

Trial Court Cause No. 1150452



MEMORANDUM OPINION



Appellant, Eric Renee Munoz, has been charged with capital murder. Bail was originally set at no bond. Appellant filed an application for writ of habeas corpus, requesting that bail be set at $75,000. After a hearing on the writ, the trial court granted habeas corpus relief, but set bail at $1,000,000. In this appeal, appellant contends the amount of bail is statutorily and constitutionally excessive and unreasonable. We affirm.

BACKGROUND

The probable cause affidavit in this case provided the following: On January 3, 2002, Sergeant W. Kuhlman arrived at the scene of a fatal shooting. Sixteen-year-old Carlos Christopher Zamudo died from a gunshot wound to the neck. A witness at the scene, Aizar Trevino, told officers that he had been driving his brother's blue Honda Accord, and that Zamudo was sitting in the passenger seat, when the two decided to stop at a Whataburger restaurant. While eating at the Whataburger, Trevino noticed a purple Escalade circle the restaurant. Shortly thereafter, a Hispanic female named Cynthia or Sandra approached their car. The girl was crying and told them that her boyfriend had kicked her out of his car. She asked Trevino and Zamudo to take her to a nearby apartment to visit a friend, which they agreed to do. As he turned into the apartment complex, Trevino again noticed the purple Escalade, which was leaving the complex. Two men then pulled guns on Trevino and Zamudo and ordered them out of the car. Trevino got out of the car and ran; he saw Zamudo on the ground and he then heard six shots being fired in Zamudo's direction. One of the men ordered the girl into Trevino's car, which then sped away. Trevino did not see the purple Escalade again, but he believed that the event was a "set up" that began at the Whataburger restaurant. The police found the stolen Honda the next day; it had been stripped of its custom wheels and rims and burned.

The crime went unsolved for several years, until Sandra Gaitan was arrested on unrelated charges. When Gaitan was interviewed, she at first claimed that she was a victim of the crime, but later admitted to being a party to Zamudo's murder. Specifically, Gaitan admitted that she had lured Trevino and Zamudo to the apartment complex so that appellant and Robert Narvez could steal their car. Narvez and appellant, armed with guns, approached Trevino and Zamudo and demanded that they get out of the car. Gaitan then saw appellant shoot Zamudo, who was unarmed.

PROPRIETY OF BAIL SETTING

In his sole point of error, appellant argues that the million-dollar bail is statutorily and constitutionally excessive and unreasonable. To determine whether the trial court abused its discretion, we consider the rules found in article 17.15 of the Texas Code of Criminal Procedure. See Tex. Code Crim. Proc. Ann. art. 17.15 (Vernon 2005).

The standard of review for reviewing bail settings is whether the trial court abused its discretion. See Ex parte Rubac, 611 S.W.2d 848, 850 (Tex. Crim. App. 1981). In the exercise of its discretion, a trial court should consider the following rules in setting a defendant's bail:

1. The bail shall be sufficiently high to give reasonable assurance that the undertaking will be complied with.



2. The power to require bail is not to be used so as to make it an instrument of oppression.



3. The nature of the offense and the circumstances under which it was committed are to be considered.



4. The ability to make bail is to be regarded, and proof may be taken upon this point.



5. The future safety of a victim of the alleged offense and the community shall be considered.



Tex. Code Crim. Proc. Ann. art. 17.15 (Vernon 2005); see Ludwig v. State, 812 S.W.2d 323, 324 (Tex. Crim. App. 1991) (noting that the court is "to be governed in the exercise of [its] discretion by the Constitution and by the [article 17.15 factors]").

The burden of proof is upon a defendant who claims bail is excessive. Rubac, 611 S.W.2d at 849; Ex parte Martinez-Velasco, 666 S.W.2d 613, 614 (Tex. App.--Houston [1st Dist.] 1984, no pet.). The primary purpose for setting bond is to secure the presence of the defendant in court at his trial. Ex parte Vasquez, 558 S.W.2d 477, 479 (Tex. Crim. App. 1977); Ex parte Bonilla, 742 S.W.2d 743, 744 (Tex. App.--Houston [1st Dist.] 1987, no pet.). The amount of bail should be set sufficiently high to give reasonable assurance that the accused will comply with the undertaking, but should not be set so high as to be an instrument of oppression. Ex parte Bufkin, 553 S.W.2d 116, 118 (Tex. Crim. App. 1977); Ex parte Willman, 695 S.W.2d 752, 753 (Tex. App.--Houston [1st Dist.] 1985, no pet.). Courts should also consider the defendant's work record, family ties, residency, past criminal record, conformity with previous bond conditions, other outstanding bonds, and aggravating factors involved in the offense. See Rubac, 611 S.W.2d at 849-50; see also Martinez-Velasco, 666 S.W.2d at 614-15.

A. Nature of the Offense

The record reflects that the State indicted appellant for capital murder for intentionally or knowingly causing the death of Carlos Zamudio with a firearm, during the course of committing and attempting to commit a robbery. See Tex. Pen. Code Ann. § 19.03(a)(2) (Vernon Supp. 2008). An offense under this statute is a capital felony. Id. § 19.03(b) (Vernon Supp. 2008). The punishment for this offense is imprisonment for life, or death, as the State is seeking the death penalty in this case. Id. § 12.31 (Vernon Supp. 2008).

Although high, other murder cases have held $1,000,000 bonds not to be excessive under certain circumstances. See Ex parte Brown

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

Related

Ex Parte Bonilla
742 S.W.2d 743 (Court of Appeals of Texas, 1987)
Ludwig v. State
812 S.W.2d 323 (Court of Criminal Appeals of Texas, 1991)
Ex Parte Vasquez
558 S.W.2d 477 (Court of Criminal Appeals of Texas, 1977)
Ex Parte Miller
631 S.W.2d 825 (Court of Appeals of Texas, 1982)
Ex Parte Rubac
611 S.W.2d 848 (Court of Criminal Appeals of Texas, 1981)
Ex Parte Martinez-Velasco
666 S.W.2d 613 (Court of Appeals of Texas, 1984)
Ex Parte Willman
695 S.W.2d 752 (Court of Appeals of Texas, 1985)
Ex Parte Dueitt
529 S.W.2d 531 (Court of Criminal Appeals of Texas, 1975)
Ex Parte Charlesworth
600 S.W.2d 316 (Court of Criminal Appeals of Texas, 1980)
Aviles v. State
23 S.W.3d 74 (Court of Appeals of Texas, 2000)
Ex Parte Williams
467 S.W.2d 433 (Court of Criminal Appeals of Texas, 1971)
Ex Parte Chavfull
945 S.W.2d 183 (Court of Appeals of Texas, 1997)
Ex Parte Harris
733 S.W.2d 712 (Court of Appeals of Texas, 1987)
Ex Parte Bufkin
553 S.W.2d 116 (Court of Criminal Appeals of Texas, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
Eric Renee Munoz v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-renee-munoz-v-state-texapp-2009.