In Re Commitment of Bryant Oliver Tutter v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 14, 2025
Docket09-23-00351-CV
StatusPublished

This text of In Re Commitment of Bryant Oliver Tutter v. the State of Texas (In Re Commitment of Bryant Oliver Tutter 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.

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In Re Commitment of Bryant Oliver Tutter v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-23-00351-CV __________________

IN RE COMMITMENT OF BRYANT OLIVER TUTTER

__________________________________________________________________

On Appeal from the 359th District Court Montgomery County, Texas Trial Cause No. 22-10-13793-CV __________________________________________________________________

MEMORANDUM OPINION

A jury unanimously found beyond a reasonable doubt that Bryant Oliver

Tutter is a sexually violent predator pursuant to the Sexually Violent Predators Act

(“SVP Act”). See Tex. Health & Safety Code Ann. §§ 841.001-.153. As a result, the

trial court civilly committed him for sex-offender treatment and supervision. Tutter

challenges the sufficiency of the evidence to support a finding beyond a reasonable

doubt that he has a behavioral abnormality that makes him likely to engage in a

1 predatory act of sexual violence. Having reviewed the record and the arguments

asserted, we affirm the trial court’s judgment and order of commitment.

Background

In 2022, the State petitioned to civilly commit Tutter under the SVP Act,

which permits commitment of individuals upon a finding that they (1) are a “repeat

sexually violent offender” and (2) suffer “from a behavioral abnormality that makes

the person likely to engage in a predatory act of sexual violence.” Id. § 841.003(a).

Tutter filed an answer denying the State’s allegations.

At trial, the State presented testimony from Dr. Michael Arambula, a clinical

and forensic psychiatrist. After detailing his training and experience in sex-offender

risk assessment, Arambula described how he met with and evaluated Tutter for the

purpose of determining whether he suffers from a behavioral abnormality that would

subject him to civil commitment under the SVP Act. Arambula explained that when

conducting a behavioral abnormality evaluation, he first reviews any records that are

sent to him and then conducts a general psychiatric examination followed by a

forensic psychiatric evaluation. Arambula confirmed he followed this methodology

in evaluating Tutter and arriving at his opinion that Tutter suffers from a behavioral

abnormality that makes him likely to engage in a predatory act of sexual violence.

2 Arambula explained that risk factors are “elements in someone’s history that

have been researched looking at the population of individuals[]” that are “based on

statistical findings.” He further explained that according to research, there is a causal

relationship between the seriousness of one’s condition and the risk of recidivism.

According to Arambula, the “heaviest” risk factor looks at the number of victims

and number of incidents. Tutter had four sexual offense convictions, but numerous

allegations which occurred over the years. The second risk factor is the degree of

someone’s antisocial personality. Tutter’s sexual deviance involved children.

Arambula also identified other risk factors for Tutter, which included reoffending

after treatment, a serious issue with alcohol at the time of his offenses, and the degree

at the time of his arrest of lack of responsibility, blaming the victims, and denial.

Arambula diagnosed Tutter with pedophilia, unspecified personality disorder

with some antisocial features, and alcohol abuse that has been in remission due to

Tutter’s incarceration. Arambula explained that to be diagnosed with pedophilic

disorder, an individual has an interest, fantasies, and/or has engaged in activity with

children that are generally thirteen and younger, the condition has persisted at least

six months, and the condition causes clinically significant impairment of distrust.

Arambula testified Tutter meets all the criteria, even though Tutter didn’t admit to

having these types of sexual fantasies during Arambula’s evaluation. According to

3 Arambula, Tutter’s diagnosis for pedophilia relates to his behavioral abnormality

because of the chronicity and the number of victims. Furthermore, there is a statically

high risk for recidivism when children are involved. Arambula testified that while

Tutter’s chronic pedophilia doesn’t go away, it can be managed and treated.

Arambula explained that an unspecified personality disorder with antisocial

features is a diagnosis where there are some, but not all, criteria for an antisocial

personality disorder. Arambula did not diagnose Tutter with antisocial personality

disorder because that diagnosis requires evidence of a history of conduct disorder

prior to reaching adulthood, and he had no evidence of that. Antisocial features

include lack of responsibility and lack of remorse. In determining that Tutter had

antisocial features, Arambula looked at a mental health evaluation administered by

psychologists in which Tutter scored somewhat high on specific aspects of antisocial

personality. Along with sexual deviance, antisocial personality tends to aggravate

the risk for sexual recidivism.

Arambula testified that Tutter made statements indicating he was under the

influence when he abused his biological daughter and his stepdaughter. Although

Arambula explained substance abuse aggravates the future risk of sexual recidivism,

he did not consider Tutter’s alcohol abuse in determining whether Tutter has a

behavioral abnormality because of the length of Tutter’s incarceration; instead, he

4 focused on the seriousness of Tutter’s sexual deviance and the number of victims

and incidents. An additional factor Arambula accounted for in determining Tutter’s

risk factors is a cognitive screen which showed Tutter has a mild cognitive

impairment. This impairment, according to Arambula, could raise the issue of

disinhibition.

The evidence admitted at trial shows that Tutter has four convictions for

sexually violent offenses: three convictions for indecency with a child and one

conviction for aggravated sexual assault of a child. Regarding the first conviction,

Arambula testified that Tutter sexually assaulted his six-year-old biological daughter

Michelle. 1 Arambula explained that his daughter reported that Tutter removed his

clothing and her clothing and fondled her in bed. There were also allegations of

attempted sex. Arambula testified that the records indicate that Tutter didn’t accept

responsibility for his actions and failed to acknowledge his actions could have

harmed Michelle. For this incident, Tutter was convicted of indecency with a child

and received a ten-year probated sentence. His probation was later revoked because

1We refer to the victims referred to in the opinion using pseudonyms to protect

their identities. See Tex. Const. art. I, § 30 (granting crime victims “the right to be treated with fairness and with respect for the victim’s dignity and privacy throughout the criminal justice process”). 5 of allegations of recurrent sexual misconduct and a failed polygraph that Tutter

agreed to take as part of his probation. He was then sentenced to ten years in prison.

Arambula identified several risk factors associated with Tutter’s first

conviction. First, Tutter’s denial and minimization of the offense is a risk factor

because research shows that it is a sign and symptom of sexual deviance. Next,

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