Ex Parte: Nicholas Tullett v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJanuary 31, 2024
Docket05-22-00845-CR
StatusPublished

This text of Ex Parte: Nicholas Tullett v. the State of Texas (Ex Parte: Nicholas Tullett 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: Nicholas Tullett v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

AFFIRMED; and Opinion Filed January 31st, 2024

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-22-00845-CR

EX PARTE NICHOLAS TULLETT

On Appeal from the County Criminal Court No. 3 Dallas County, Texas Trial Court Cause No. MC22A0578

MEMORANDUM OPINION Before Justices Molberg, Reichek, and Smith Opinion by Justice Smith Nicholas Tullett appeals the denial of his application for habeas corpus by a

visiting judge. We affirm the judge’s order.

Background

In July 1996, appellant entered a negotiated plea of no contest to public

lewdness. In accordance with the terms of the plea agreement, the trial court

convicted appellant and assessed a sentence of ninety days’ confinement, suspended

the sentence, and placed appellant on community supervision for twelve months.

In February 2022, appellant filed an application for writ of habeas corpus,

challenging the 1996 conviction and seeking to withdraw his plea. See TEX. CODE CRIM. PROC. ANN. art. 11.072. The State filed a response, and, thereafter, the parties

appeared before a visiting judge for a hearing on the application. Appellant objected

to the visiting judge presiding over the matter. Arguing that habeas proceedings

were legally distinct from criminal proceedings, counsel asserted that section

74.053(b) of the Texas Government Code, which authorizes objections to visiting

judges in civil actions, should apply. See TEX. GOV’T CODE ANN. § 74.053(b). The

visiting judge overruled the objection and, after receiving testimony from appellant

and hearing the arguments of counsel, denied appellant’s application for habeas

relief. This appeal followed.

Standard of Review

We review statutory interpretation, a question of law, de novo. State v.

Kahookele, 640 S.W.3d 221, 225 (Tex. Crim. App. 2021). In doing so, we look to

the “literal text and attempt to discern its fair, objective meaning.” Id. (citing Boykin

v. State, 818 S.W.2d 782, 785 (Tex. Crim. App. 1991)). “We give effect to the plain

meaning of the statutory text, reading it in context and construing it according to the

rules of grammar and common usage.” Id. We also give effect to “each word,

phrase, clause, and sentence if reasonably possible” and assume each word has been

used purposely. Id. If a statute is clear and unambiguous, we may not add or subtract

from it. Boykin, 818 S.W.2d at 785. We may consider extratextual factors only if

“the language is ambiguous or would lead to absurd consequences that the

Legislature could not possibly have intended.” Kahookele, 640 S.W.3d at 225.

–2– Applicable Statutes

Chapter 11 of the Texas Code of Criminal Procedure governs applications for

writs of habeas corpus. See TEX. CODE CRIM. PROC. ANN. ch. 11. Article 11.072

provides the exclusive means by which district courts may exercise original habeas

jurisdiction in cases involving an individual who is either serving, or has completed,

a term of community supervision. See id. art. 11.072; Ex parte Villanueva, 252

S.W.3d 391, 397 (Tex. Crim. App. 2008).

Chapter 74 of the Texas Government Code authorizes the assignment of

retired and former judges, provided they meet certain statutory requirements, “to

hold court when necessary to dispose of accumulated business in [an administrative

judicial] region.” TEX. GOV’T CODE ANN. §§ 74.052, 74.054, 74.055. However,

“[i]f a party to a civil case files a timely objection to the assignment, the judge shall

not hear the case.” Id. § 74.053(b) (emphasis added).

Analysis

In three issues, appellant contends that the visiting judge abused her discretion

in overruling his objection to her presiding over his habeas proceeding. Specifically,

appellant asserts that the hearing was a civil proceeding and, therefore, pursuant to

the government code, his objection rendered the visiting judge disqualified to

preside.

Appellant properly filed his application under article 11.072, which

establishes the habeas procedures for a defendant in a felony or misdemeanor case

–3– who seeks relief from an order or judgment of conviction ordering community

supervision. See TEX. CODE CRIM. PROC. ANN. art. 11.072, § 1. The Court of

Criminal Appeals has not specifically addressed whether article 11.072 proceedings

are criminal proceedings. However, it has determined that proceedings under article

11.07, which governs habeas applications seeking relief from a felony judgment

imposing a sentence other than death, are “categorized as criminal proceedings by

statute.” Ex parte Rieck, 144 S.W.3d 510, 516 (Tex. Crim. App. 2004); see also

Aranda v. Dist. Clerk, 207 S.W.3d 785, 786 (Tex. Crim. App. 2006) (per curiam)

(vexatious litigant statute in Texas Civil Practice and Remedies Code does not apply

to article 11.07 proceeding, which is criminal, not civil, in nature).

In Rieck, the Court of Criminal Appeals observed that “courts have struggled

with how to characterize habeas proceedings and have sometimes characterized

them as ‘neither civil nor criminal but rather sui generis’ or ‘an exercise of special

constitutional and statutory jurisdiction.’” 144 S.W.3d at 516 (citations omitted).

Likewise, the Court recognized that, in Texas, a habeas proceeding is considered

“separate from the criminal prosecution—being a collateral, rather than direct, attack

on the judgment of conviction.” Id. The Court noted, however, that “Texas has gone

further in eschewing the civil label for habeas proceedings arising from criminal

prosecutions or convictions” and categorizes such proceedings as criminal for

jurisdictional purposes. Id. And, because section 5 of article 11.07 confers on the

Court of Criminal Appeals the exclusive authority to grant post-conviction habeas

–4– relief after a final felony conviction, an article 11.07 habeas proceeding also is

categorized a criminal proceeding by statute. Rieck, 144 S.W.3d at 516.

Unlike article 11.07, article 11.072 does not provide the Court of Criminal

Appeals with exclusive authority to grant habeas relief. Article 11.072’s plain

language, however, similarly reflects the criminal nature of habeas proceedings in

which a defendant seeks relief from an order or judgment of conviction ordering

community supervision. Specifically, it requires that an applicant who wishes to

appeal a trial court’s denial of habeas relief must follow Texas Code of Criminal

Procedure article 44.02, which governs a criminal defendant’s right to appeal, and

Texas Rule of Appellate Procedure 31, which governs appeals in habeas corpus, bail,

and extradition proceedings “in criminal cases” and provides for the availability of

a petition for discretionary review to the Court of Criminal Appeals. See TEX. CODE

CRIM. PROC. ANN. arts. 11.072, §8, 44.02; TEX. RS. APP. P. 31.4, 31.5; see also TEX.

RS. APP. P. 31.1, 31.2 (providing that appellate court should use the same briefing

rules and deadlines, submission schedules, and hearing schedules that apply to direct

appeals from criminal cases in an appeal from a habeas corpus proceeding

challenging a conviction or an order placing the defendant on community

supervision).

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

Related

Ex Parte Villanueva
252 S.W.3d 391 (Court of Criminal Appeals of Texas, 2008)
Gibson v. State
921 S.W.2d 747 (Court of Appeals of Texas, 1996)
Ex Parte Tarango
116 S.W.3d 201 (Court of Appeals of Texas, 2003)
Ex Parte Rieck
144 S.W.3d 510 (Court of Criminal Appeals of Texas, 2004)
Aranda v. District Clerk
207 S.W.3d 785 (Court of Criminal Appeals of Texas, 2006)
Boykin v. State
818 S.W.2d 782 (Court of Criminal Appeals of Texas, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
Ex Parte: Nicholas Tullett v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-nicholas-tullett-v-the-state-of-texas-texapp-2024.