George Oliver McKnight v. State

CourtCourt of Appeals of Texas
DecidedDecember 17, 2009
Docket14-08-00770-CR
StatusPublished

This text of George Oliver McKnight v. State (George Oliver McKnight v. State) 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
George Oliver McKnight v. State, (Tex. Ct. App. 2009).

Opinion

Affirmed as Reformed and Memorandum Opinion filed December 17, 2009.

In The

Fourteenth Court of Appeals

NO. 14-08-00770-CR

George Oliver McKnight, Appellant

v.

The State of Texas, Appellee

On Appeal from the 177th District Court

Harris County, Texas

Trial Court Cause No. 1149919

MEMORANDUM OPINION

Appellant George Oliver McKnight challenges his conviction for robbery.  In two issues, appellant claims the trial court erred in denying his motions to suppress a pretrial line-up identification and in allowing an in-court identification because the complainant viewed photos of appellant before identifying him in a line-up.  In a third issue, appellant argues the trial court erred in admitting extraneous-offense evidence in violation of Texas Rules of Evidence 403 and 404(b).  We reform the judgment as requested in the State’s sole cross-point to reflect the jury’s affirmative finding of appellant’s use of a deadly weapon in the commission of the robbery, and we affirm the judgment as reformed.

I.  Factual and Procedural Background

A police officer arrived at a gas station in response to a call about a robbery.  At the scene, the officer spoke with complainant Keith Piatkowski.  Piatkowski explained to the officer that he had stopped at the gas station that morning to fuel his truck.  Piatkowski was standing behind the truck when he first noticed a man at a nearby bus stop.  Piatkowski saw the man slowly walk towards his truck. 

The man was wearing a white t-shirt and blue jeans.  Piatkowski described the man as a person of mixed Hispanic-Caucasian descent, who was 25 to 30 years of age with an average build, and a height of 5’6” to 5’7”.  Piatkowski guessed that the man weighed between 150 and 160 pounds.  According to Piatkowski’s description, the man was clean shaven, had dark brown to black hair, wore his hair short on the sides and one to two inches long on top, and that his hair was a “little wavy.”  Piatkowski gave this description of the man to a responding officer and later to an investigator. 

According to Piatkowski, the man made a “dash” to open the truck’s door on the driver’s side.  Piatkowski attempted to meet the man at the door.  The man brushed shoulders with Piatkowski, and the man elbowed Piatkowski to keep him away.  Although the truck’s doors were closed, the door was unlocked and the keys were inside.  Once inside the truck, the man locked the doors.  Piatkowski stared at the man through the window and then walked in front of the truck.  The man started the ignition and drove forward, hitting Piatkowski.  Piatkowski rolled across the hood of the truck and grabbed the mirror and then the side railing of the truck in an attempt to get into the truck bed.  The man the driving the truck dragged Piatkowski for an undisclosed distance before Piatkowski released his grip, and the man drove the truck from the scene.  In Piatkowski’s mind, the ordeal lasted approximately three minutes.

Several weeks later, the abandoned truck was located.  Piatkoski went to retrieve the vehicle and met police officers at the location.  The truck had sustained heavy damage with dents and graffiti.  Officers took fingerprints from the truck before it was towed to a body shop and ultimately released to Piatkowski. 

In January 2008, an investigator contacted Piatkowski about the case.  Piatkowski gave the investigator a description of the man who stole the truck.  Investigators had matched a fingerprint taken from the truck to a woman named Kathy Respress.  The investigator determined that Piatkowski’s description of the man at the gas station resembled appellant’s description.  Investigators knew that appellant was a friend of Respress’s.  The investigator indicated that she wanted to conduct a live line-up based on this information.  In their conversation, the investigator learned that Piatkowski had cleaned out the truck and found a notebook, a letter, and a disposable camera inside.  Piatkowski had offered to develop the film from the camera; Piatkowski’s girlfriend had the film processed the next day. 

When Piatkowski met with the investigator to view the line-up, he gave the photos and other items taken from the truck to the investigator.  Piatkowski acknowledged that he viewed the photos before he arrived at the police station.  Several of the photos depicted appellant inside the stolen truck; one of the photos depicted Respress inside the stolen truck.  Piatkowski recognized the man in the photo as the person who stole the truck. 

The investigator conducted the line-up about one hour later.  According to the investigator, appellant was permitted to select some of the participants in the line-up and he determined the participants’ placement in the line-up.  From the line-up, Piatkowski identified appellant as the person who stole the truck.  Piatkowski immediately recognized appellant in the line-up and remained confident in his identification of appellant. 

Appellant was charged with robbery, to which he pleaded “not guilty.”  He filed two motions.  In the first motion, appellant challenged the identification procedure before the line-up, alleging that the Houston Police Department exhibited a set of photographs to Piatkowski for the purpose of identifying appellant.  In the second motion, appellant objected to the admission of Piatkowski’s in-court identification of him, claiming that the State had insufficient means to identify him and that any identification of him was based on hearsay and an improper, suggestive “photographic line-up.”  The trial court denied both motions. 

Following a trial on the merits, a jury found appellant guilty as charged.  The jury also found that appellant used a deadly weapon, a motor vehicle, in committing the offense.  After finding two enhancement paragraphs to be true, the jury assessed appellant’s punishment at thirty-two years’ confinement. 

II.  Issues and Analysis

A.    Did the trial court err in denying appellant’s challenges to the pre-trial identification and the in-court identification?

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George Oliver McKnight v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/george-oliver-mcknight-v-state-texapp-2009.