in Re Commitment of Seth Hill

CourtCourt of Appeals of Texas
DecidedFebruary 28, 2013
Docket09-11-00593-CV
StatusPublished

This text of in Re Commitment of Seth Hill (in Re Commitment of Seth Hill) 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 Seth Hill, (Tex. Ct. App. 2013).

Opinion

In The

Court of Appeals Ninth District of Texas at Beaumont _________________ NO. 09-11-00593-CV _________________

IN RE COMMITMENT OF SETH HILL

________________________________________________________________________

On Appeal from the 435th District Court Montgomery County, Texas Trial Cause No. 08-01-00790 CV ________________________________________________________________________

MEMORANDUM OPINION

The State of Texas petitioned for Seth Hill‟s commitment after it received a

psychologist‟s report that Hill is a sexually violent predator. See Tex. Health &

Safety Code Ann. §§ 841.001-.151 (West 2010 & Supp. 2012) (SVP Statute).

Following a trial, a jury found that Hill suffers from a behavioral abnormality that

makes him likely to engage in a predatory act of sexual violence. The trial court

rendered a final judgment and an order of civil commitment. On appeal, Hill raises

14 issues challenging the judgment. We find Hill‟s issues are without merit and

affirm the trial court‟s judgment.

1 I. Admissibility of Testimony

The State designated three experts to testify at trial: A.P. Merrillat, a

fingerprint analyst; Dr. Timothy Proctor, a board-certified forensic psychologist

and a licensed sex offender treatment provider; and Dr. Michael R. Arambula, a

board-certified forensic psychiatrist. Hill designated Dr. John Tennison, who is a

licensed psychiatrist. Hill raises issues related to each expert‟s testimony, as well

as issues related to his own testimony. We address the issues as they correspond to

each witness below.

A. Testimony of A.P. Merrillat

In issue one, Hill argues that the trial court erred in refusing to allow him to

cross-examine the State‟s fingerprint expert, A.P. Merrillat, on the prison

conditions Merrillat observed while working for the Special Prosecution Unit

investigating crimes that occur within prisons. The State called Hill as its first

witness and questioned him extensively regarding his sexual activity and numerous

sexual misconducts during his term of imprisonment. In an attempt to rebut this

evidence, Hill‟s counsel attempted to cross-examine Merrillat “about conditions

that [Hill] would have faced inside the prison system, his access to various

temptations, stressors, triggers[.]” The State objected and argued that this

testimony was not relevant, and that Merrillat was only designated as a fingerprint

2 expert. The trial court ruled that Hill‟s counsel could ask foundational questions as

to whether Merrillat had dealings with Hill personally, and if so, Merrillat could

testify as to the things he personally witnessed. The trial court allowed counsel to

pursue the matter with Merrillat in an offer of proof.

In the offer of proof, Merrillat testified generally regarding the availability

of drugs and alcohol in prison, as well as the types of sexual activities that occur in

the prison environment. He testified that it is a violation of prison policy for

inmates to engage in sexual activity. He agreed that the disciplinary process in

prison is dependent on guards making allegations, which are sometimes untrue or

exaggerated. He also testified that inmates make false accusations. At the

conclusion of Hill‟s offer, the trial court sustained the State‟s objection.

We review the trial court‟s determination to exclude Merrillat‟s proffered

testimony for an abuse of discretion. Osbourn v. State, 92 S.W.3d 531, 537-38

(Tex. Crim. App. 2002). Rule 701 of the Texas Rules of Evidence provide the

guidelines for opinion testimony by lay witnesses. Tex. R. Evid. 701. It requires

opinion testimony to be rationally based on the witness‟s perception and helpful to

a clear understanding of the witness‟s testimony or the determination of a fact in

issue. Id. “Both lay and expert witnesses can offer opinion testimony.” Osbourn,

92 S.W.3d at 535. “A person with specialized knowledge may testify about his or

3 her own observations under Rule 701 and may also testify about the theories, facts

and data used in his or her area of expertise under Rule 702.” Id. at 536. An expert

may provide testimony under Rule 701 “„if the witness‟s testimony and opinion are

based upon firsthand knowledge.‟” Id. at 536 (quoting Texas Rules of Evidence

Manual art. VII-6-7 (6th ed. 2002)).

The trial judge ruled that Merrillat‟s testimony regarding the prison

environment and the propensity of false allegations of crimes and other violations

committed therein, were not based on Merrillat‟s personal knowledge, but rather

were based on hearsay. Because Merrillat‟s observations about the types of

activities that occur in the prison environment are not based on a scientific theory,

his testimony is admissible only as a lay opinion, if it meets the requirements of

Rule 701. If Merrillat perceived the events and then formed an opinion that a

reasonable person could draw from the facts, the first part of Rule 701 is satisfied.

See Tex. R. Evid. 701.

It is not entirely clear from Merrillat‟s testimony or the offer of proof

whether he personally perceived the events forming the basis of his opinions, or

whether he obtained information regarding the events second hand. Regardless,

what is clear is that Merrillat‟s testimony did not relate specifically to the prisons

in which Hill had been incarcerated. Therefore, Merrillat‟s testimony does not

4 meet this requirement of Rule 701. Moreover, the same testimony defense counsel

sought to elicit from Merrillat regarding the prison conditions, defense counsel was

able to ask without objection of Dr. Proctor, therefore any error would be harmless.

See Tex. R. App. P. 44.1(a). Finding no abuse of discretion, we overrule this issue.

B. Testimony of Dr. Thomas Proctor

In two issues, Hill claims the trial court abused its discretion in denying him

the right to fully cross-examine Proctor. In his second issue, Hill claims that he

was denied the right to cross-examine Proctor regarding his understanding of the

law as it informs his opinion that Hill suffers from a behavioral abnormality. In his

fourth issue, Hill argues the trial court denied him the right to cross-examine

Proctor on the rate of error for his methodology in determining whether a person is

likely to sexually recidivate.

Rule 702 of the Texas Rules of Evidence provides that “[i]f scientific,

technical, or other specialized knowledge will assist the trier of fact to understand

the evidence or to determine a fact in issue, a witness qualified as an expert by

knowledge, skill, experience, training, or education may testify thereto in the form

of an opinion or otherwise.” Tex. R. Evid. 702. An expert may base his or her

opinions or inferences on facts or data that are of a type reasonably relied upon by

experts in the particular field. Tex. R. Evid. 703. An expert may be required to

5 disclose on cross-examination the underlying facts or data that support his or her

opinions or inferences in a case. Tex. R. Evid. 705(a). The trial court has discretion

to restrict cross-examination to matters shown to be relevant, as well as to avoid

the needless consumption of time. See Tex. R. Evid. 611(a)(1)(2), (b).

1. Cross-Examination Regarding the SVP Statute and Case Law

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