Ex Parte James Richards v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJune 27, 2024
Docket09-24-00077-CV
StatusPublished

This text of Ex Parte James Richards v. the State of Texas (Ex Parte James Richards v. the State of Texas) 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
Ex Parte James Richards v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-24-00077-CV __________________

EX PARTE JAMES RICHARDS

__________________________________________________________________

On Appeal from the 435th District Court Montgomery County, Texas Trial Cause No. 24-01-01465-CV __________________________________________________________________

MEMORANDUM OPINION

James Richards filed a notice of appeal of an order denying an application for

a writ of habeas corpus, and in the brief he filed to support his appeal he complains

the trial court erred in denying the Application for Writ of Habeas Corpus (the

“application”), which he filed with the trial court during January 2024. In his

application, Richards alleged that he “is civilly committed pursuant to Texas Health

& Safety Code Chapter 841.” The application Richards filed argues that the 2015

Amendments to Chapter 841 should not have been applied to him, and he argues that

the statute, as applied to him, is unconstitutional. After receiving the notice of appeal

1 and docketing the appeal, the Clerk of the Court questioned this Court’s jurisdiction.

Richards responded and argued this Court could exercise appellate jurisdiction

because the trial court had ruled on the merits of the application. In the alternative,

Richards asked the Court to consider granting mandamus relief should the Court find

that appellate jurisdiction was lacking over his appeal.

For the reasons explained below, we conclude the trial court did not rule on

the merits of Richards’ application for a writ of habeas corpus. We also conclude the

trial court did not abuse its discretion in denying the application and that Richards is

not entitled to relief under his alternative argument asking the Court to treat his

appeal as a petition for mandamus. We dismiss the appeal and deny the petition for

a writ of mandamus.

Background

In his application for a writ of habeas corpus, Richards alleged he is in the

custody of Marsha McLane, Executive Director of the Texas Civil Commitment

Office (TCCO) and that he is “unlawfully confined and restrained in his liberty at

the Texas Civil Commitment Center[.]” Richards stated that he was civilly

committed in 2003 in the 221st District Court of Montgomery County, Texas. See

Tex. Health & Safety Code Ann. §§ 841.001–.209 (the SVP Act). Richards claimed

the 2015 amendments to the SVP Act, which the 84th Legislature passed as Senate

Bill Number 746 (S.B. 746), are unconstitutional as applied to him because the

2 enactment language of S.B. 746, subsection 40(a), made the law prospective only

and he was civilly committed as a sexually violent predator before June 17, 2015,

the effective date of S.B. 746. Richards attached to his application an order, signed

on September 15, 2015, amending the order of civil commitment to require the

TCCO to provide Richards with sex offender treatment and supervision pursuant to

section 841.0831 of the Health and Safety Code. Richards alleged his involuntary

residence in the Texas Civil Commitment Center is illegal because section 12 of S.B.

746, which deleted references to “outpatient” treatment, and section 16 of S.B. 746,

which created a tiered treatment program and required incarceration in a “total

confinement facility” in newly enacted section 841.0831 of the Health and Safety

Code, should not apply to him because he was already subject to civil commitment

under the SVP Act on June 17, 2015. Richards asked the trial court to issue the writ

of habeas corpus and order McLane to release Richards from confinement in the

Texas Civil Commitment Center and “provide him treatment and supervision in a

manner other than in confinement.” Richards requested a videoconference hearing

in the trial court on his application for a writ of habeas corpus.

In a response opposing Richards’ application for a writ of habeas corpus, the

State explained that the 2003 amendments to the SVP Act added subsection

841.082(e), which provided, “[t]he requirements imposed under Subsection (a) may

be modified at any time after notice to each affected party to the proceedings and a

3 hearing.” See Act of May 30, 2003, 78th Leg., R.S., ch. 347, 2003 Tex. Gen. Laws

1505, 1516-17. The State attached a copy of an order, signed December 7, 2010, that

modified the final judgment and order of civil commitment to require that Richards

reside in a Texas Residential facility under contract with the predecessor agency or

at another location or facility approved by the agency. The State also attached a

waiver of right to notice and hearing of the change made by S.B. 746 and amended

order of civil commitment, signed on September 15, 2015, that ordered the TCCO

to provide Richards with appropriate sex offender treatment and necessary

supervision pursuant to section 841.0831 of the Health and Safety Code, and ordered

Richards to reside where instructed by TCCO and participate in and comply with the

TCCO sex offender treatment program. The State argued that the 2015 amendments

to the SVP Act required the TCCO to operate a tiered treatment program that began

with total confinement and had tiers of treatment that could then transition to

possible release from civil commitment. The State argued the S.B. 746 enactment

language that applied to Richards was subsection 40(b), which required the trial

court to modify Richards’ civil commitment order and place Richards in the tiered

treatment program.

On February 1, 2024, the trial court denied Richards’ application for a writ of

habeas corpus and his motion for a hearing. The trial court signed the order after

reviewing the application, the motion for a hearing, the State’s response, and “all

4 other documents related to Richards’ application.” The order included recitals

finding “there are no controverted, previously unresolved facts material to the

legality of Richards’ civil commitment” and the trial court had found “legal authority

overruling Richards’ arguments in his application.”

On February 9, 2024, Richards filed a motion to strike the State’s response to

his application for a writ of habeas corpus. Richards claimed the Special Prosecution

Unit (SPU) lacked statutory authorization to represent the State in a habeas corpus

proceeding, argued that he had inadvertently served the Montgomery County

District Attorney, and that on February 5, 2024, he served Respondent McLane by

serving the General Counsel of the TCCO by regular mail. Richards submitted a

proposed order that is contained in the clerk’s record and remains unsigned.

On February 21, 2024, Richards mailed a notice of appeal that was received

by the District Clerk within ten days and filed on February 28, 2024. Upon receiving

the notice of appeal, the Clerk of the Court of Appeals issued a notice questioning

whether the appellate court had jurisdiction to consider the appeal. In response,

Richards argued he could appeal the order because the trial court had ruled on the

merits of the habeas corpus application. He argued that, although the trial court

declined to issue the writ, it had considered the facts argued in the application and

considered the arguments raised in Richards’ application. Finally, Richards asked

that this Court consider his request in the alternative as seeking a writ of mandamus.

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