Fabian Andres Aranda Rodriguez v. the State of Texas

Court of Appeals of Texas·Decided August 13, 2025·No. 04-24-00246-CR·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-24-00246-CR

Fabian Andres ARANDA RODRIGUEZ, Appellant

v.

The STATE of Texas,

Appellee

From the 175th Judicial District Court, Bexar County, Texas Trial Court No. 2022CR8360 Honorable Catherine Torres-Stahl, Judge Presiding

Opinion by: Lori Massey Brissette, Justice

Sitting: Irene Rios, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: August 13, 2025 AFFIRMED Appellant Fabian Aranda Rodriguez was indicted on one count of murder. After a four-day jury trial, he was found guilty and the trial court sentenced him to life imprisonment. He appeals his conviction on three grounds: (1) improper admission of a video containing his statements while in custody; (2) improper discharge of a juror for cause; and (3) ineffective assistance of counsel. We affirm.

BACKGROUND

Appellant was convicted of stabbing his mother, Maritza Rodriguez, thirty-six times in the face and neck while she was staying with him at an Airbnb. Over the course of four days, the jury heard from seventeen witnesses, including Aranda Rodriguez himself. The jury heard the 911 calls and saw photos and video of the crime scene, including of Ms. Rodriguez’s body, a bloodied bed, and blood splatter on the walls and ceiling. They saw photos and video of the kitchen where knives were missing from the storage block and of the backyard trash can where police found a bloodied towel, t-shirt, pants, shoes, and knife. They saw Ring videos as well as videos of the hallway, kept by the Airbnb owner, showing Aranda Rodriguez arrive at the home, his movements throughout his stay, his wearing the clothes and carrying the towel later found in the trash can, and his attempts to get into another room in which another Airbnb guest was staying after his mother was killed. The video evidence also revealed no one else entered the room in which Ms. Rodriguez was killed. The jury also saw photos of Aranda Rodriguez post-arrest with scratches on his forearms and hands. They were shown a forensic serology report and a forensic DNA report and heard testimony concluding the DNA found on the bloodied items matched Ms. Rodriguez and Aranda Rodriguez. 1 Aranda Rodriguez took the stand in his own defense, admitting he stabbed his mother but explaining that he thought he was being attacked. After his mother was killed, Aranda Rodriguez left the Airbnb in an Uber, requiring the Airbnb owner to use his spare key to access the room and find Ms. Rodriguez’s body. Aranda Rodriguez was arrested the next day at San Antonio International Airport where he stated he was planning to fly to Miami.

1 The actual testimony, given how DNA testing works, is that neither of them could be excluded along with the extremely remote odds that someone else in the general population would similarly match.

ADMISSION OF VIDEO EVIDENCE OF STATEMENTS MADE WHILE IN CUSTODY First, Aranda Rodriguez argues on appeal the trial court improperly admitted a video taken of him in the homicide investigation room at the San Antonio Police Department because the record does not demonstrate he knowingly, intelligently and voluntarily waived his Miranda rights. 2 See Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602 (1966); TEX. CODE CRIM. PROC. art. 38.22. Specifically, Aranda Rodriguez contends that the nodding of his head when asked if he understood the reading of his rights was not sufficient to demonstrate that he understood or that he knowingly, intelligently, and voluntarily waived those rights when he later decided to speak. The State contends the totality of the circumstances, as set forth in the video, demonstrates his knowing, intelligent, and voluntary waiver. The trial court made findings of fact and conclusions of law supporting its ruling to admit the video. 3 The court found the following after reviewing the video and after hearing the testimony of Sergeant Juarez who read Aranda Rodriguez his rights and interacted with him afterwards:

• Sergeant Juarez was a credible witness and spoke fluent Spanish.

• Defendant’s demeanor was calm, quiet and cooperative.

2 At trial, Aranda Rodriguez’s counsel first objected to the video, after taking the police officer on voir dire, on the basis that the video does not demonstrate that Aranda Rodriguez understood his rights or made a knowing, intelligent and voluntary waiver of his rights. After the video was admitted and after it had played for a time before the jury, defense counsel objected that the video contained hearsay, specifically the statements of Juan Aranda—Aranda Rodriguez’s brother. The trial court overruled that objection saying it was untimely. Defense counsel then objected that there was no translation of what Aranda Rodriguez was saying, but because he had failed to request a transcript and translation prior to trial that objection was overruled as well. On appeal, Aranda Rodriguez abandons those arguments, arguing in his brief only that the nod of his head was insufficient to demonstrate that he understood his rights. 3 We remanded this case to allow the trial court to make the required findings of fact and conclusions of law pursuant to Texas Code of Criminal Procedure article 38.22, section 6. “In all cases where a question is raised as to the voluntariness of a statement of an accused, the court . . . must enter an order stating its conclusion as to whether or not the statement was voluntarily made, along with the specific finding of facts upon which the conclusion was based, which order shall be filed among the papers of [the] cause.” TEX. CODE. CRIM. PROC. art. 38.22 § 6. As recognized by the Texas Court of Criminal Appeals, such findings are mandatory and required in all cases where voluntariness of a statement is raised as an issue. Vasquez v. State, 411 S.W.3d 918, 920 (Tex. Crim. App. 2013) (holding court of appeals committed error by not abating for such findings). “The statute has no exceptions.” Id.

• Sergeant Juarez’s demeanor was friendly and conversational, and was never hostile, confrontational, aggressive, or threatening toward Defendant.

• In response to Sergeant Juarez asking Defendant if he understood his rights, Defendant, although it was subtle, clearly and unambiguously nodded and mumbled what was unmistakably an affirmative response.

• During the remainder of the first portion of the interview Defendant said nothing.

When Sergeant Juarez returned and after he spoke with Defendant’s brother on the telephone in front of Defendant, Defendant ultimately spoke with Sergeant Juarez.

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