In Re Commitment of Nathaniel Hawkins v. the State of Texas

CourtCourt of Appeals of Texas
DecidedApril 15, 2025
Docket01-23-00570-CV
StatusPublished

This text of In Re Commitment of Nathaniel Hawkins v. the State of Texas (In Re Commitment of Nathaniel Hawkins 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
In Re Commitment of Nathaniel Hawkins v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

Opinion issued April 15, 2025

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00570-CV ——————————— IN RE COMMITMENT OF NATHANIEL HAWKINS

On Appeal from the 177th District Court Harris County, Texas Trial Court Case No. 0727433-0101Z

MEMORANDUM OPINION

This is a civil-commitment action under the Sexually Violent Predators Act

(“SVP Act”). See TEX. HEALTH & SAFETY CODE §§ 841.001–.209. The State of

Texas brought this case to have Nathaniel Hawkins civilly committed for

involuntary treatment and supervision as a sexually violent predator. The jury

unanimously found in favor of Hawkins, and the trial court entered judgment on the jury’s verdict. The State raises a single issue on appeal, arguing the trial court

improperly denied it the right to present a rebuttal argument in closing. We affirm.

I. The SVP Act

The SVP Act requires the State to prove that a person is a “sexually violent

predator” before he can be civilly committed. See id. § 841.062. A sexually violent

predator is someone who (1) is a “repeat sexually violent offender” and (2) “suffers

from a behavioral abnormality that makes [him] likely to engage in a predatory act

of sexual violence.” Id. § 841.003(a). A person is a repeat sexually violent offender

if he is convicted of more than one “sexually violent offense” and a sentence is

imposed on at least one of those convictions. Id. § 841.003(b). A behavioral

abnormality is a “congenital or acquired condition that, by affecting a person’s

emotional or volitional capacity, predisposes the person to commit a sexually violent

offense, to the extent that the person becomes a menace to the health and safety of

another person.” Id. § 841.002(2). The State must prove these elements “beyond a

reasonable doubt,” and in a jury trial, the verdict must be unanimous. Id. § 841.062.

II. Background

At trial, the State presented testimony from two witnesses: Hawkins and Dr.

Christine Reed, a clinical and forensic psychologist who evaluated Hawkins for a

behavioral abnormality under the SVP Act. The State also presented documentary

evidence in the form of Dr. Reed’s curriculum vitae and three “penitentiary packets”

2 reflecting Hawkins’ convictions and sentences. Other than his cross-examination of

Dr. Reed and his direct testimony, Hawkins did not present any evidence.

A. “Repeat sexually violent offender” element

Regarding the “repeat sexually violent offender” element, the State introduced

evidence that Hawkins had been convicted of two sexually violent offenses. First,

in 1972, he was convicted of rape for which he was sentenced to ten years’

confinement. This conviction involved an incident when Hawkins was seventeen

years old and working at a cemetery. The victim, a sixty-nine-year-old woman, was

placing flowers on her deceased husband’s grave when Hawkins attacked her with

his fists, raped her, locked her in the trunk of her car, and then drove her to a nearby

parking lot. Hawkins generally denied that he committed the offense to Dr. Reed

and at trial.

Second, in 1997 and when he was forty-two years old, Hawkins was convicted

of aggravated sexual assault of a child for which he was sentenced to thirty-five

years’ confinement. This conviction involved an instance in which Hawkins was

babysitting his eleven-year-old niece. Hawkins masturbated in front of her in a car

and then made her get in the back seat, where he sexually and physically assaulted

her. The niece escaped and told police Hawkins was smoking crack before the

incident. Again, Hawkins generally denied that he committed the offense to Dr.

Reed and at trial.

3 B. “Behavioral abnormality” element

To establish the “behavioral abnormality” element, the State relied on Dr.

Reed’s testimony. Dr. Reed testified that after completing her education, she began

working in the field of forensic psychology in 2008 and has been a forensic

psychologist ever since. Dr. Reed explained that in her role as a forensic

psychologist, she does not perform therapeutic work with patients aimed at

rehabilitation; instead, her practice consists exclusively of assessments and

evaluations for use in the legal system or in the employment-screening context. On

cross-examination, Dr. Reed testified that her last involvement in the treatment of

patients was during a fellowship in 2007, that she is not board certified in forensic

psychology, and that she has not published in the field of sexually violent predators

or performed research in recidivism. She has not previously testified for the defense

in a civil-commitment proceeding. Dr. Reed testified that she has conducted

approximately ninety behavioral-abnormality evaluations.

To conduct her behavioral-abnormality evaluation of Hawkins, Dr. Reed

reviewed Hawkins’ criminal-history records, his medical- and mental-health

records, his prison records, and notes from his sex-offender treatment. She also

interviewed him twice, once in January 2021 and again in November 2022. Those

interviews were conducted via videoconference; Dr. Reed never met with Hawkins

in person. Nor did she speak to Hawkins’ family members or friends. Dr. Reed

4 testified she did not get a “complete history” for Hawkins, but she “feel[s] like [she]

got an adequate history.”

Based on her assessment, Dr. Reed opined that Hawkins suffers from a

behavioral abnormality. She reached this opinion because Hawkins displayed the

two most significant risk factors for sexual recidivism: sexual deviance and an

antisocial lifestyle. Dr. Reed testified that sexual deviance is “sexual behavior that

significantly deviates from the norm,” and an antisocial lifestyle is one that is marked

by a person’s “persistent disregard [for] or violation of the rights of others.” Dr.

Reed came to these conclusions based in part on Hawkins’ criminal history.

Dr. Reed considered it significant that Hawkins’ victim in the 1972 rape was

a stranger, because “[h]aving victims that are strangers to you is considered a risk

factor for re-offending.” She also considered the following offenses significant

because Hawkins has engaged in criminal behavior beyond sexual offenses as

somebody “that violates the rules,” which is evidence of anti-sociality.

In 1980, about a year after he was released from prison for the 1972 rape

conviction, Hawkins was convicted of false imprisonment for using a firearm to

restrain his wife. Hawkins told Dr. Reed that he was separated from his wife at the

time, that she had become jealous of him, and that “he just didn’t have any time for

it.” Dr. Reed characterized Hawkins’ explanation as “minimiz[ing] his behavior”

5 and “not taking responsibility for his actions.” Hawkins received a sentence of six

months in jail for this offense.

In 1990, Hawkins was convicted of two counts of criminal mischief and two

counts of aggravated assault on a police officer, stemming from an incident in which

he kicked in the window of his girlfriend’s car and then attacked the police officers

who apprehended him. Hawkins testified he had no recollection of this incident.

In 1994, when Hawkins was forty-one, he was convicted of indecent exposure

and indecency with a child by exposure. These convictions stemmed from an

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