Ex Parte Michael Joseph Bennett

CourtCourt of Appeals of Texas
DecidedOctober 18, 2007
Docket02-07-00175-CR
StatusPublished

This text of Ex Parte Michael Joseph Bennett (Ex Parte Michael Joseph Bennett) 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 Michael Joseph Bennett, (Tex. Ct. App. 2007).

Opinion

COURT OF APPEALS

SECOND DISTRICT OF TEXAS

FORT WORTH

NO. 2-07-175-CR

EX PARTE MICHAEL JOSEPH

BENNETT                                                                                          

------------

FROM THE 89TH DISTRICT COURT OF WICHITA COUNTY

MEMORANDUM OPINION[1]

I.  Introduction

This is an appeal from the denial of habeas corpus relief seeking bond reduction.  Appellant Michael Joseph Bennett contends in a sole point that his bonds are excessive in violation of the Eighth Amendment to the United States Constitution; article I, section 13 of the Texas Constitution; and article 17.15 of the Texas Code of Criminal Procedure.  We will affirm.


II.  Procedural Background


Bennett is incarcerated on three counts[2] of aggravated sexual assault of a child.  The trial court set Bennett=s bail at $200,000 on each count.[3]  Bennett filed an application for writ of habeas corpus to reduce bail, asserting that the bail amount was excessive and requesting that it be reduced to a $10,000 surety bond.  The trial court held a hearing on Bennett=s habeas application requesting bail reduction during which Bennett appeared to argue that his bond should be lowered to $25,000 because his mother testified that she could make a $25,000 bond.  The trial court denied the requested relief.  This appeal from the denial of Bennett=s application for writ of habeas corpus to reduce bail followed.

III.  Excessive Bail

A.     Standard of Review

We review the trial court=s denial of a bond‑reduction request under an abuse of discretion standard.  See Ex parte Rubac, 611 S.W.2d 848, 850 (Tex. Crim. App. [Panel Op.] 1981); Ex parte Scott, 122 S.W.3d 866, 868 (Tex. App.CFort Worth 2003, no pet.); see also Tex. Code Crim. Proc. Ann. art. 17.15 (Vernon 2005) (giving trial court discretion to set amount of bond).  To determine whether a trial court abused its discretion, we must decide whether the trial court acted without reference to any guiding rules or principles; in other words, we must decide whether the act was arbitrary or unreasonable. Montgomery v. State, 810 S.W.2d 372, 380 (Tex. Crim. App. 1990).  Merely because a trial court may decide a matter within its discretion in a different manner than an appellate court would in a similar circumstance does not demonstrate that an abuse of discretion has occurred.  Id.

B.     Reasonable Bail Factors


The primary purpose of an appearance bond is to secure the presence of the defendant at trial on the offense charged.  Ex parte Vasquez, 558 S.W.2d 477, 479 (Tex. Crim. App. 1977); Scott, 122 S.W.3d at 868.  Accordingly, bail should be set high enough to give reasonable assurance that the defendant will appear at trial, but it should not operate as an instrument of oppression.  Scott, 122 S.W.3d at 868.  In a habeas proceeding, the burden of proof is on the defendant to show that the bail, as set, is excessive.  Rubac, 611 S.W.2d at 849.

Article 17.15 of the Texas Code of Criminal Procedure sets forth the following criteria for establishing a defendant=s bond:

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 so used 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.  In addition to these factors, the court should also weigh the following factors in determining the amount of the bond:  (1) the accused=s work record; (2) the accused=s family ties; (3) the accused=s length of residency; (4) the accused=s prior criminal record, if any; (5) the accused=

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Related

Ex Parte Hunt
138 S.W.3d 503 (Court of Appeals of Texas, 2004)
Ex Parte Vasquez
558 S.W.2d 477 (Court of Criminal Appeals of Texas, 1977)
Ex Parte Hulin
31 S.W.3d 754 (Court of Appeals of Texas, 2000)
Ex Parte Rubac
611 S.W.2d 848 (Court of Criminal Appeals of Texas, 1981)
Ex Parte Brown
959 S.W.2d 369 (Court of Appeals of Texas, 1998)
Ex Parte Scott
122 S.W.3d 866 (Court of Appeals of Texas, 2003)
Montgomery v. State
810 S.W.2d 372 (Court of Criminal Appeals of Texas, 1991)
Ex Parte Davila
623 S.W.2d 408 (Court of Criminal Appeals of Texas, 1981)

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Ex Parte Michael Joseph Bennett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-michael-joseph-bennett-texapp-2007.