Ex Parte William Jackson

CourtCourt of Appeals of Texas
DecidedJanuary 13, 2011
Docket14-10-00982-CR
StatusPublished

This text of Ex Parte William Jackson (Ex Parte William Jackson) 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 William Jackson, (Tex. Ct. App. 2011).

Opinion

Affirmed and Memorandum Opinion filed January 13, 2011.

In The

Fourteenth Court of Appeals

____________

NO. 14-10-00979-CR

NO. 14-10-00980-CR

NO. 14-10-00981-CR

NO. 14-10-00982-CR

NO. 14-10-00983-CR

EX PARTE WILLIAM JACKSON

On Appeal from the 176th District Court

Harris County, Texas

Trial Court Cause Nos. 1280592, 1280593, 1280594, 1280595, & 1280596

M E M O R A N D U M   O P I N I O N

William Jackson has been charged with five felony offenses.  After originally denying bail, the trial court set pre-trial bail totaling $810,000.  Jackson filed a pre-trial application for writ of habeas corpus seeking a reduction of the bonds.   See Tex. Code Crim. Proc. art. 11.24.  The trial court denied relief, and this appeal followed.  See Tex. R. App. P. 31.  We affirm.

Background

Jackson has been charged with the following: two charges of tampering with governmental records in cause numbers 1187829 and 1187830; engaging in organized criminal activity in cause number 1231219, forgery-fraudulent use or possession of identifying information in cause number 1261302, and being a felon in possession of a firearm in cause number 1261303.  Engaging in organized crime is a first degree felony.  The tampering and forgery charges are second degree felonies, and the weapon charge is a third degree felony.  The State enhanced each indictment, alleging Jackson had twice before committed sequential felony offenses.  The trial court originally denied bail after a hearing in May of 2009, and a record of that hearing has been filed in this appeal. [1]   At some point not identified in our record, the trial court set pre-trial bail at $80,000 each in cause numbers 1187829 and 118730, $350,000 in cause number 1231219, $200,000 in cause number 1261302, and $100,000 in cause number 1261303, for a total bail amount of $810,000.[2]  On July 21, 2010, Jackson filed a pre-trial application for writ of habeas corpus seeking a reduction of the bonds to $30,000, $30,000, $50,000, $30,000, $20,000, respectively, for a total bail amount of $160,000.  Jackson has not provided a record from any subsequent hearing on the issue of bail.[3]  Our record contains an order stating that on September 17, 2010, the trial court considered and denied Jackson’s pre-trial application for writ of habeas corpus seeking a bail reduction.  The trial court then signed a judgment denying relief in each cause.

At the May hearing, the State established that Jackson was arrested in September 2009 while a search warrant was being executed.  According to the State, Jackson was creating false checks and fraudulent driver’s licenses, and he was in possession of a large number of passport photos and a large amount of cash.  Jackson made bond on the original charges.

After reviewing the computer confiscated pursuant to the search warrant, the police discovered evidence of identity theft.  During a subsequent search at Jackson’s home, police discovered a gun in the nightstand drawer of the room where Jackson slept, and Jackson was arrested again.  New charges of forgery and felon in possession of a weapon were filed. 

Standard of Review

In two issues, Jackson contends that the trial court abused its discretion in denying his request to lower his bonds.  He alleges generally that bail is oppressively high, in violation of the state and federal constitutions, without asserting any specific constitutional arguments.

We review a trial court’s ruling on the setting of bond under an abuse of discretion standard of review.  See Ex parte Rubac, 611 S.W.2d 848, 850 (Tex. Crim. App. 1981); Milner v. State, 263 S.W.3d 146, 147 (Tex. App.—Houston [1st Dist.] 2006, no pet.)  A defendant who seeks a reduction in the amount of bond has the burden of proof to demonstrate that the bond is excessive.  Maldonado v. State, 999 S.W.2d 91, 93 (Tex. App.—Houston [14th Dist.] 1999, pet. ref’d).  A writ applicant has the burden to ensure that a sufficient record is presented to show error requiring reversal.  See Ex parte Kimes, 872 S.W.2d 700, 703 (Tex. Crim. App. 1993).  An appellate court may not reduce the trial court’s bail amount unless the applicant has satisfied this burden.  Ex parte Welch, 729 S.W.2d 306, 310 (Tex. App.—Dallas 1987, no pet.) (refusing to reduce bail amount when reviewing court found, after considering evidence and factors relevant to determining amount of bond, that “applicant has failed to satisfy his burden of showing that the trial court abused its discretion in refusing to lower applicant’s bond”).

Considerations in Settling Bail

The primary purpose of an appearance bond is to secure the accused’s presence at trial on the charged offense.  Id.  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.  Id.  Bail set at an amount higher than reasonably calculated to fulfill this primary purpose is excessive under the Eighth Amendment.  In re Durst, 148 S.W.3d 496, 498 (Tex. App.—Houston [14th Dist.] 2004, no pet.).  

While the decision regarding a proper bail amount lies within the sound discretion of the trial court, the court is required to consider criteria set forth in article 17.15 of the Texas Code of Criminal Procedure, which provides as follows:

The amount of bail to be required in any case is to be regulated by the court, judge, magistrate or officer taking the bail; they are to be governed in the exercise of this discretion by the Constitution and by the following rules:

1.

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Ex Parte William Jackson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-william-jackson-texapp-2011.