Ex Parte MacK Watson

Court of Appeals of Texas·Decided December 22, 2020·No. 01-19-00637-CR·Published

Opinion

Opinion issued December 22, 2020

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-19-00637-CR ——————————— EX PARTE MACK WATSON, JR., Appellant

On Appeal from the 263rd District Court Harris County, Texas Trial Court Cause No. 1640628

MEMORANDUM OPINION

Appellant, Mack Watson, Jr., challenges the trial court’s order denying his

application for a writ of habeas corpus. In a single issue, appellant asserts the trial

court erred in denying his application for writ of habeas corpus, in which he argued

that double jeopardy precludes his retrial for murder.

We affirm. Background

Watson pleaded not guilty to a murder for which he was indicted in 2016. A

jury was empaneled on July 12, 2019 and told to return for opening arguments the

following week. On July 15, 2019, the day before opening arguments were

scheduled to begin, the State learned of the existence of dashboard camera video

footage (“dashcam video”) from a Harris County deputy constable who the State

was interviewing in preparation for his trial testimony. The constable told the State

during the interview there may be dashcam video of the traffic stop during which

Watson was arrested shortly after the homicide. Upon calling his precinct, the

constable confirmed the existence of the footage.

That same morning the State advised Watson’s counsel that the dashcam

video existed. The prosecutor obtained a copy of the video that day, invited

Watson’s counsel to watch it while a copy was made for him, and gave him the copy

of the dashcam video. The State contends it had no reason to believe the dashcam

video existed until then, given that the offense report did not mention the video and

defense counsel never specifically requested the dashcam video. Watson asserts he

requested the dashcam video during discovery.

On July 16, 2019, the trial court convened a hearing on the late-discovered

evidence. The State advised the court it had contacted other agencies involved in the

murder investigation and the traffic stop and found that fifteen other potentially

2 relevant videos existed. The State obtained them and produced them to Watson that

day. Also during the hearing, Watson complained of the State’s failure to produce

“a 3-D diagram of the scene,” which the State called a “Leica scan.” The parties

disagreed as to whether the Leica scan was actually a “scene diagram” and whether

the defense had specifically requested it or been entitled to it without a specific

request under article 39.14 of the Texas Code of Criminal Procedure.1

Regardless, it is undisputed that the State produced offense reports to Watson,

that the reports specifically referred to the Leica scan, and that the State produced a

1 Article 39.14 of the Code of Criminal Procedure states in pertinent part: [A]s 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 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. ... [T]he state shall disclose to the defendant any exculpatory, impeachment, or mitigating document, item, or information in the possession, custody, or control of the state that tends to negate the guilt of the defendant or would tend to reduce the punishment for the offense charged. TEX. CODE CRIM. PRO. art. 39.14 (a), (h).

3 number of materials Watson’s counsel requested after viewing the offense reports.

The State told the trial court during the hearing that, given that the Leica scan was

specifically mentioned in the offense report, the request for a “scene diagram” rather

than a “Leica scan” had been construed as “a paper copy of a scene diagram.” The

State also said it had “tendered the entire State’s file to the defense” more than once.

During the hearing, Watson’s counsel requested a continuance until July 22,

2019 so he could review the newly produced materials.2 The State opposed the

continuance to July 22, 2019 because its DNA expert had travel plans that week, but

the State agreed to a continuance until July 29, 2019 and provided several other

scheduling options, none of which was acceptable to the defense, for commencing

the trial with the same jury while giving Watson’s counsel sufficient time to review

the newly produced materials. For example, the State offered to allow its DNA

expert, who had “nothing to do with the dash cam or any of the scene evidence,” to

2 Watson’s counsel said during the July 22, 2019 hearing that the Leica scan, which he had yet to view because of technical difficulties, was “very, very important to the defense” because it could show where shell casings landed and the bullets’ trajectory, potentially pointing to another shooter. Watson argues in his appeal that “the discovery requested [went] to the very heart of the defense, i.e. where the shots came from and who was firing first from where,” but his brief does not identify how the dashcam video or Leica scan was exculpatory or cite to the record in support of his argument. The State, on the other hand, contends that while the dash cam video and Leica scan were material, they were not exculpatory. Specifically, the State asserts “the dash cam tracks exactly what is in the offense report, nothing different,” and the Leica scan only showed “what the scene looked like.”

4 testify by deposition before leaving town or to testify live on July 19, 2019, so the

remainder of the trial could begin the week of July 22, 2019. Watson maintained he

could not question any witnesses before having sufficient time to review the newly

discovered materials. The trial court polled the jury to determine whether trial could

begin on July 29, 2019, but several jurors had conflicts on that date. Watson then

said:

At this point we don’t have a jury that would be available to hear this case and we would ask for a mistrial based on the fact that we just now are getting new evidence that we have to review.

The State expressed reservations about a mistrial, but the trial court granted

Watson’s motion.

On July 19, 2019, Watson filed an application for writ of habeas corpus,

asserting (1) jeopardy had attached because the State had acted in such a way as to

cause a mistrial, causing the court to order one sua sponte,3,4 and (2) the trial court

3 The court’s findings of fact and conclusions of law confirm Watson moved for the mistrial. Watson concedes in his appeal that “the [d]efense . . . requested the mistrial. . . .” 4 Even though Watson had moved for the mistrial, he said in his application in the trial court that a mistrial was not necessary because the trial court had several options to allow testimony to begin July 22, 2019 or July 29, 2019.

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

Ex Parte MacK Watson, (Tex. Ct. App. 2020).

Ex Parte MacK Watson (Ex Parte MacK Watson) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Oregon v. Kennedy
456 U.S. 667 (Supreme Court, 1982)
Kniatt v. State
206 S.W.3d 657 (Court of Criminal Appeals of Texas, 2006)
Ex Parte Lewis
219 S.W.3d 335 (Court of Criminal Appeals of Texas, 2007)
Ex Parte Peterson
117 S.W.3d 804 (Court of Criminal Appeals of Texas, 2003)
Ex Parte Wheeler
203 S.W.3d 317 (Court of Criminal Appeals of Texas, 2006)
Ex Parte Masonheimer
220 S.W.3d 494 (Court of Criminal Appeals of Texas, 2007)
Ex Parte Wheeler
122 S.W.3d 170 (Court of Criminal Appeals of Texas, 2003)
Sandifer v. State
233 S.W.3d 1 (Court of Appeals of Texas, 2007)
Ex Parte Amezquita
223 S.W.3d 363 (Court of Criminal Appeals of Texas, 2006)
State of Texas v. Guerrero, Ex Parte Marcelino
400 S.W.3d 576 (Court of Criminal Appeals of Texas, 2013)
Arango v. State
518 S.W.3d 916 (Court of Appeals of Texas, 2017)