In Re: The Commitment of Raul Villegas Garza v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJanuary 16, 2025
Docket02-24-00208-CV
StatusPublished

This text of In Re: The Commitment of Raul Villegas Garza v. the State of Texas (In Re: The Commitment of Raul Villegas Garza 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: The Commitment of Raul Villegas Garza v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-24-00208-CV ___________________________

IN RE: THE COMMITMENT OF RAUL VILLEGAS GARZA

On Appeal from the 355th District Court Hood County, Texas Trial Court No. C2022596

Before Sudderth, C.J.; Bassel and Womack, JJ. Memorandum Opinion by Chief Justice Sudderth MEMORANDUM OPINION

Appellant Raul Villegas Garza challenges his civil commitment as a sexually

violent predator, see Tex. Health & Safety Code Ann. Ch. 841 (the SVP Act), raising a

single issue in which he argues there was legally insufficient evidence to support the

jury’s verdict that he has a behavioral abnormality making him likely to engage in

future predatory acts of sexual violence. Because the evidence is sufficient to support

the jury’s verdict, we will affirm.

I. INTRODUCTION

The State filed a petition to civilly commit Garza as an SVP based on his

previous convictions and sentences on four counts of indecency with a child by

contact under Section 21.11(a)(1) of the Texas Penal Code. All four are considered

sexually violent offenses for purposes of the SVP Act.1 See id. § 841.002(8)(A). Garza

had also been subsequently convicted of one count of tampering with or fabricating

evidence under Texas Penal Code Section 37.03, which is not a sexually violent

offense for purposes of the SVP Act, but which was a factor in the analysis of his risk

Garza was convicted by a jury of two offenses of indecency with a child by 1

contact against each of two child victims, four offenses in total, in 2004. He was sentenced to 20 years’ confinement for each offense, to be served concurrently.

2 to reoffend due to its relation to his previous indecency convictions.2 See infra Section

II.A.

Besides Garza, only one other witness testified at the jury trial: the State’s

expert, Dr. Jason D. Dunham, Ph.D. Dr. Dunham testified that Garza is a repeat

sexually violent offender and suffers from a behavioral abnormality that predisposes

him to engage in predatory acts of sexual violence. In contrast, Garza testified that he

did not commit any of the offenses for which he was convicted, will not commit

future offenses, and is and always has been incapable of sexually assaulting anyone.

The jury rejected Garza’s contention, answering “Yes” to the charge question,

“Do you find beyond a reasonable doubt that [Garza] is a sexually violent predator?”

The trial court then ordered Garza civilly committed in accordance with Section

841.081 of the Texas Health and Safety Code, and this appeal followed.

II. BACKGROUND

At a trial on a State’s petition seeking civil commitment, the jury shall

determine whether they believe beyond a reasonable doubt that the person is an SVP.

Id. § 841.062(a). A person is an SVP if that person “(1) is a repeat sexually violent

In 2014, while incarcerated for his previous offenses, Garza was convicted by 2

a jury of tampering with or fabricating evidence and sentenced him to 20 years’ confinement, concurrent with his previously imposed sentence.

3 offender;3 and (2) suffers from a behavioral abnormality that makes the person likely

to engage in a predatory act of sexual violence.” Id. § 841.003(a)(1), (2). “Behavioral

abnormality” is statutorily defined as “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).

A commitment proceeding under the SVP Act is the rare civil proceeding that

incorporates the “beyond a reasonable doubt” burden of proof typical of criminal

cases. See id. § 841.062; In re Commitment of Fisher, 164 S.W.3d 637, 639–41 (Tex. 2005).

Legal-sufficiency review in civil cases with this burden is consistent with review in

criminal cases: the reviewing court must determine “whether, after viewing the

evidence in the light most favorable to the prosecution, any rational trier of fact could

have found the essential elements of the crime beyond a reasonable doubt.” In re

Commitment of Stoddard, 619 S.W.3d 665, 674–75 (Tex. 2020) (quoting Jackson v. Virginia,

443 U.S. 307, 319, 99 S. Ct. 2781, 2789 (1979)).

In addition to testimony, the evidence at trial consisted of Dr. Dunham’s

curriculum vitae and the penitentiary packet containing judgments from Garza’s four

3 A repeat sexually violent predator is a person who is convicted of more than one sexually violent offense for which a sentence is imposed for at least one. Tex. Health & Safety Code Ann. § 841.003(b).

4 convictions for indecency with a child by contact and his conviction for tampering

with or fabricating evidence.

A. Dr. Dunham’s Testimony

Dr. Dunham is a licensed forensic psychologist. His decades’ long practice

consists of evaluations and consultations in legal proceedings, specializing in sex

offender evaluations. At the time of trial, he had performed 321 evaluations in sex

offender cases in Texas.

In conducting civil commitment evaluations, Dr. Dunham reviews an

individual’s records, interviews the individual, conducts testing, and reviews test

results to evaluate the individual’s risk of reoffending. Dr. Dunham testified that in

evaluating Garza, he used methodology that accords with his training as a forensic

psychologist and that he believes is within the accepted standards in the field of

forensic psychology.

After reviewing Garza’s pertinent records, Dr. Dunham prepared a profile in

preparation for his first interview with Garza, then honed his opinion as he received

new information. Dr. Dunham evaluated Garza using a clinically adjusted actuarial

approach incorporating the Static-99R, an actuarial test, and adjusted for observed

behaviors that were not reflected in the test.

Dr. Dunham interviewed Garza twice. The first interview lasted approximately

90 minutes, which Dr. Dunham considered adequate to conduct an initial evaluation.

Based on his review of the records and his first interview with Garza, Dr. Dunham

5 formed the belief, based upon his training, education, and experience, that Garza has

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

violence. After receiving additional information about unindicted and unadjudicated

allegations and other alleged victims, Dr. Dunham met with Garza a second time,

about a year later. His initial beliefs remained unchanged after the second interview.

Based upon his education, training, experience, and methodology used, Dr.

Dunham determined that Garza suffers from a behavioral abnormality that makes

him likely to engage in predatory acts of sexual violence. More specifically, Dr.

Dunham found in his document review and interviews that Garza suffers from the

behavioral abnormality of paraphilic disorder, a chronic sexually deviant attraction to

prepubescent and pubescent girls, and shows traits of antisocial personality disorder.4

1. Convictions for Sexual Offenses

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Golden Eagle Archery, Inc. v. Jackson
116 S.W.3d 757 (Texas Supreme Court, 2003)
In Re Commitment of Fisher
164 S.W.3d 637 (Texas Supreme Court, 2005)

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In Re: The Commitment of Raul Villegas Garza v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-commitment-of-raul-villegas-garza-v-the-state-of-texas-texapp-2025.