Eudalia Bonilla v. State

CourtCourt of Appeals of Texas
DecidedJune 3, 2010
Docket14-08-00289-CR
StatusPublished

This text of Eudalia Bonilla v. State (Eudalia Bonilla 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
Eudalia Bonilla v. State, (Tex. Ct. App. 2010).

Opinion

Affirmed and Substitute Memorandum Opinion filed June 3, 2010.

In The

Fourteenth Court of Appeals

___________________

NO. 14-08-00289-CR

EUDALIA BONILLA, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 239th District Court

Brazoria County, Texas

Trial Court Cause No. 51,110

SUBSTITUTE MEMORANDUM OPINION

A jury convicted appellant, Eudalia Bonilla, of felony theft amounting to at least $1,500.00 but less than $20,000.00 (aggregated).  In seven issues, appellant contends the evidence is legally insufficient to support the jury’s verdict, her due process rights were violated, and the trial court erred in denying her request for a jury instruction on mistake of law and overruling her objection to the prosecutor’s closing argument.  We affirm.

I.   Background

            Appellant is the mother of four children, including C.B., a female who was fourteen-years-old at the time of trial.  Linda Nesmith is C.B.’s paternal grandmother and has had legal custody of C.B. since 1997. 

            In July 2004, Nesmith was interviewed by Texas Health and Human Services Commission (“HHSC”) eligibility specialist Debbie Brock regarding Nesmith’s eligibility for benefits, including food-assistance benefits for C.B.  Brock discovered C.B. was already the subject of a benefits claim by appellant.  Nesmith told Brock that C.B. had lived with her for several years and presented court documents establishing her legal custody of C.B.  Brock notified appellant that she would no longer be allowed to claim C.B. as part of her household for benefits purposes.  Appellant did not respond to the notice.

            Appellant’s alleged food-stamp fraud was referred to Kameshia McCoy, a senior fraud investigator with HHSC.  McCoy concluded from her investigation that appellant’s fraudulent activities began in April 2002.  She also concluded appellant was overissued $4,093.43 from HHSC as a result of wrongfully claiming benefits for C.B.

            Appellant was indicted for felony theft-aggregated.  Following a jury trial and conviction, appellant entered into a plea agreement relative to punishment.

II.   Analysis

A.        Legal Sufficiency of the Evidence

We begin by addressing appellant’s issues challenging legal sufficiency of the evidence supporting the jury’s verdict.  In her first issue, appellant contends the evidence is legally insufficient to support the jury’s finding that she deceived HHSC by claiming C.B. as part of her household because an incorrect legal standard was used by the State and trial court for determining that C.B. did not “live with” appellant.  In her third issue, appellant contends the evidence is legally insufficient to support the jury’s finding that she was deceptive during the entire period of time the State examined to determine the aggregate amount of alleged theft.  In her fourth issue, appellant contends the evidence is legally insufficient to support the jury’s finding that she had the requisite criminal intent to commit theft.

In determining legal sufficiency, we view all of the evidence in the light most favorable to the verdict and decide whether a trier of fact could have found each element of the offense beyond a reasonable doubt.  Young v. State, 14 S.W.3d 748, 753 (Tex. Crim. App. 2000).  The jury is the exclusive judge of the credibility of witnesses and the weight to be given their testimony; it is the exclusive province of the jury to reconcile conflicts in the evidence.  Wesbrook v. State, 29 S.W.3d 103, 111 (Tex. Crim. App. 2000).  Thus, when performing a legal-sufficiency review, we may not re-evaluate the weight and credibility of the evidence and substitute our judgment for that of the factfinder.  Dewberry v. State, 4 S.W.3d 735, 740 (Tex. Crim. App. 1999).  A factfinder may disbelieve some or all of a witness’s testimony, even when that testimony is uncontradicted.  Hernandez v. State, 161 S.W.3d 491, 501 (Tex. Crim. App. 2005).  We must resolve any inconsistencies in the testimony in favor of the verdict.  Curry v. State, 30 S.W.3d 394, 406 (Tex. Crim. App. 2000).

1.         Food-Stamp Eligibility Standards

We first consider whether the evidence is legally sufficient to support the contention that the correct legal standard was used for determining whether appellant and C.B. lived together.  Interpretation of federal food-stamp law and regulations is a question of law we consider de novoSee Anderson v. State, 193 S.W.3d 34, 38 (Tex. App.—Houston [1st Dist.] 2006, pet. ref’d) (“Statutory interpretation is a question of law.”); see also In re R.C.T., No. 14-07-00642-CV, 2009 WL 2517054, at *2 (Tex. App.—Houston [14th Dist.] June 18, 2009, pet. filed) (mem. op.) (interpreting state and federal statutory language de novo).

The parties agree that a “household” eligible to receive food stamps is defined in the federal regulations, in pertinent part, as,

[A] group of individuals who live together and customarily purchase food and prepare meals together for home consumption.

[P]arents and their children 21 years of age or younger who live together, and children . . . under 18 years of age who live with and are under the parental control of a person other than their parent together with the person exercising parental control shall be treated as a group of individuals who customarily purchase and prepare meals together for home consumption even if they do not do so.

7 U.S.C.A. § 2012(i) (West 1999) (emphasis added), amended by Farm Security and Rural Investment Act of 2002, Pub. L. No. 107-171, § 4112(b)(1), 116 Stat. 134, 312–13 (2002)

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