In Re Jonathan Irving Hitt v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 7, 2024
Docket09-22-00022-CV
StatusPublished

This text of In Re Jonathan Irving Hitt v. the State of Texas (In Re Jonathan Irving Hitt 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 Jonathan Irving Hitt v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

________________

NO. 09-22-00022-CV ________________

IN RE JONATHAN IRVING HITT

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Original Proceeding 435th District Court of Montgomery County, Texas Trial Cause No. 09-10-09978-CV ________________________________________________________________________

MEMORANDUM OPINION

Jonathan Irving Hitt (“Hitt”), who is civilly committed to treatment as a

sexually violent predator, filed a Notice of Appeal requesting relief from an order

dated January 10, 2022, signed by the 435th District Judge of Montgomery County,

Texas.1 In the January 2022 order, the judge denied Hitt’s First Amended

Unauthorized Petition for Release, stating that Hitt’s biennial review showed that

1 Hitt was found to be a sexually violent predator following a trial in a civil commitment proceeding in April 2010. See In re Commitment of Hitt, No. 09-10- 00295-CV, 2011 WL 5988024 (Tex. App.—Beaumont Dec.1, 2011 pet. denied) (mem. op.). 1 “although progress was being made, the court did not find that Petitioner’s

behavioral abnormality had changed to the extent that he was no longer likely to

engage in a predatory act of sexual violence.” Hitt had argued that he “no longer has

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

violence” and, as such, should be released “from the custody and supervision of the

Texas Civil Commitment Office.” The order stated that Hitt asserts the same

argument as was “considered and rejected” in his biennial review. 2 Hitt subsequently

filed a Notice of Appeal. In his initial brief to this Court, Hitt argued his unauthorized

petition for release was not frivolous, when coupled with the uncontroverted expert

report stating that he no longer suffers from a behavioral abnormality. Hitt argues

that this court’s opinion in Keen provides a legal and factual basis for his relief

sought. 3 In November 2022, following this Court’s opinion in Welsh, Hitt filed a

supplemental brief agreeing that this Court lacks jurisdiction to hear this case as an

original Petition for Review, but requested his petition be converted to a petition for

writ of mandamus. 4 Hitt argues in his supplemental brief that the trial court abused

2 See Tex. Health & Safety Code Ann. § 841.123(b) (requiring the trial court to review and issue a ruling on a sexually violent predator’s unauthorized petition for release). 3 In re Commitment of Keen, 462 S.W.3d 524 (Tex. App.—Beaumont 2015, no pet.), overruled by In re Commitment of Welsh, 661 S.W.3d 861, 867 (Tex. App— Beaumont 2022, pet. denied). This Court overruled Keen after Hitt filed his brief. 4 In re Commitment of Welsh, 661 S.W.3d 861, 866 (Tex. App—Beaumont 2022, pet. denied) (“No statute specifically authorizes a party to appeal from a trial court’s ruling denying an unauthorized petition for release.” But explaining that the 2 its discretion by denying his relief in light of a favorable expert report and the

expert’s opinion that Hitt “no longer meets the legal standard of having a behavioral

abnormality[.]” As Hitt’s issues have not changed in his original brief and

supplemental brief, and considering our opinion in Welsh, and the Supreme Court of

Texas’s directive in CMH Homes v. Perez, we will grant Hitt’s request to consider

his petition as a petition for writ of mandamus. See In re Commitment of Welsh, 661

S.W.3d 861 (Tex. App—Beaumont 2022, pet. denied); CMH Homes v. Perez, 340

S.W.3d 444, 452 (Tex 2011) (explaining the appellant “invoked the court of appeals’

appellate jurisdiction by specifically requesting that its appeal be treated as a

mandamus petition.”); In re Commitment of Renshaw, 672 S.W.3d 426, 427-28 (Tex.

2023) (citing CMH Homes to direct the court of appeals to consider the appellant’s

habeas corpus as a petition for writ of mandamus); In re Commitment of Black, 594

S.W.3d 590, 594 (Tex. App.—San Antonio 2019, no pet.).

Standard of Review

We may issue a writ of mandamus to remedy a clear abuse of discretion by

the trial court when the relator lacks an adequate remedy by appeal. See In re

Prudential Ins. Co. of Am., 148 S.W.3d 124, 135-36 (Tex. 2004) (orig. proceeding);

Walker v. Packer, 827 S.W.2d 833, 839-40 (Tex. 1992) (orig. proceeding). “A trial

petitioner could seek mandamus relief that the trial court abused its discretion by denying his unauthorized petition as frivolous). 3 court clearly abuses its discretion if ‘it reaches a decision so arbitrary and

unreasonable as to amount to a clear and prejudicial error of law.’” Walker, 827

S.W.2d at 839. A trial court also abuses its discretion if it fails to correctly analyze

or apply the law, because a trial court has no discretion in determining what the law

is or applying it to the facts. See In re Prudential, 148 S.W.3d at 135.

Unauthorized Petition for Release

Hitt is not entitled to mandamus relief. As elaborated on below, the trial court,

when ruling on Hitt’s unauthorized petition for release, did not abuse its discretion

by concluding that the psychologist’s report Hitt filed with his unauthorized petition

for release, in conjunction with its review of Hitt’s case, failed to raise an issue of

material fact as to whether Hitt is no longer likely to engage in a predatory act of

sexual violence.

The report Hitt attached to both his unauthorized petition for release and his

petition for mandamus was prepared by Dr. Baron Crespo, a chief psychologist of

the Modern Psychological Network, whom the Texas Civil Commitment Office

(TCCO) retained for Hitt’s Biennial Examination Review. The report provides that

Crespo graduated with M.S. and Psy.D. in Clinical Psychology and a post doctorate

in Clinical Psychopharmacology. The report states that Crespo is licensed to practice

in Alabama, Texas, and Wisconsin, and Crespo is certified as a Sex Offender

Treatment Provider and the Association of State and Provincial Psychology Boards.

4 The report notes that Hitt was seen for a biennial examination on June 1, 2021, and

that Hitt consented to the examination. Crespo’s report states that Hitt was found to

be a sexually violent predator, and the report notes that Hitt was civilly committed

in 2010. Crespo states he conducted a one-hour, in-person, interview with Hitt,

reviewed Hitt’s TCCO’s records and file, including previous biennial reviews,

polygraphs and a current penile plethysmograph. The report then states that Crespo

weighed Hitt’s risk and protective factors. As to Crespo’s observations, his report

states:

Here, Examinee does not meet the standard of for civil commitment under Texas Health and Safety Code, Title 11, Chapter §841 because he no longer has an increased risk to commit a sexually violent offense, because:

• Emotionally, over the last five years, Examinee made meaningful treatment progress and reached Tier Levcl-4. Examinee’s levels of psychopathy was low during this evaluation. He showed no symptoms of psychosis, severe depression, severe anxiety or substance abuse.

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Related

In Re Prudential Insurance Co. of America
148 S.W.3d 124 (Texas Supreme Court, 2004)
CMH HOMES v. Perez
340 S.W.3d 444 (Texas Supreme Court, 2011)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
in Re Commitment of Paul Keen
462 S.W.3d 524 (Court of Appeals of Texas, 2015)

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In Re Jonathan Irving Hitt v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jonathan-irving-hitt-v-the-state-of-texas-texapp-2024.