Jacori Devon Chandler v. the State of Texas

Opinion

Court of Appeals

Tenth Appellate District of Texas

10-25-00022-CR

Jacori Devon Chandler,

Appellant

v.

The State of Texas,

Appellee

On appeal from the

County Court at Law of Navarro County, Texas Judge Amanda Doan Putman, presiding Trial Court Cause No. C41376-CR

JUSTICE HARRIS delivered the opinion of the Court.

MEMORANDUM OPINION

Jacori Devon Chandler was convicted of evading arrest or detention with a motor vehicle and sentenced to seven years in prison. His sentence was suspended, and he was placed on community supervision for seven years. We affirm the trial court’s judgment. BRADY EVIDENCE In this first issue, Chandler complains that the trial court erred in failing

2

to order the State to comply with Chandler’s Brady request. See Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963). Specifically, Chandler wanted the trial court to require the State to run criminal history checks on all of its witnesses and to provide Chandler those results.

Neither Brady nor article 39.14 of the Texas Code of Criminal Procedure (which Chandler includes in his argument on this issue) requires the State to search for exculpatory material or create any document for the defendant. See Diez v. State, 693 S.W.3d 899, 922 (Tex. App.—Austin 2024, no pet.) (State not required to perform the type of forensic analysis on cell phone that defendant wanted); In re State ex rel. Munk, 448 S.W.3d 687, 692-93 (Tex. App.—Eastland 2014, orig. proceeding) (prosecution need not have performed search on database of criminal histories); In re Watkins, 369 S.W.3d 702, 706-07 (Tex. App.—Dallas 2012, orig. proceeding) (same); see also Mitchell v. State, No. 01- 23-00251-CR, 2024 Tex. App. LEXIS 312, at *15-17 (Tex. App.—Houston [1st Dist.] Jan. 18, 2024, no pet.) (not designated for publication) (State has no independent duty per Brady or article 39.14 to seek out information for the defendant); Coleman v. State, 577 S.W.3d 623, 634-35 (Tex. App.—Fort Worth 2019, no pet.) (similar conclusion under article 39.14); cf. Harm v. State, 183 S.W.3d 403, 407 (Tex. Crim. App. 2006) (under Brady, “the [S]tate is not required to seek out exculpatory evidence independently on appellant's

3

behalf”). Chandler’s first issue is overruled. MOTION FOR NEW TRIAL Chandler next complains that the trial court erred in denying his motion for new trial based on an apparent disciplinary action regarding one prosecutor for the State which occurred in a different case after Chandler’s conviction. Chandler provides no case authority or record citations to support his complaint. See TEX. R. APP. P. 38.1(i); Neville v. State, 622 S.W.3d 99, 104 (Tex. App.—Waco 2020, no pet.). Thus, this issue is improperly briefed and presents nothing for review. See id.; Solis v. State, 726 S.W.3d 394, 412 (Tex. Crim. App. 2025); Lucio v. State, 351 S.W.3d 878, 896 (Tex. Crim. App. 2011); Busby v. State, 253 S.W.3d 661, 673 (Tex. Crim. App. 2008) (affirming that this Court has no obligation “to construct and compose” a party's “issues, facts, and arguments with appropriate citations to authorities and to the record” (internal quotes omitted)). VOIR DIRE In his last issue, Chander asserts the trial court erred in denying him the opportunity to conduct voir dire on a subject directly relevant to the State’s theory of the case: that Chandler ran because he was in possession of marijuana. Chandler wanted to question the jury about the legal difference between hemp and marijuana.

4

A trial court has broad discretion over the voir dire process. Samaripas v. State, 454 S.W.3d 1, 5 (Tex. Crim. App. 2014); Barajas v. State, 93 S.W.3d 36, 38 (Tex. Crim. App. 2002). Its discretion is abused only when a proper question about a proper area of inquiry is prohibited. Id.

Here, before the start of voir dire, the State objected to Chandler’s potential use of a slide in his voir dire presentation about the “Farm Bill of 2018” regarding the regulation of hemp. The State argued that the regulation was irrelevant to the offense of evading arrest and to whether Chandler was lawfully detained. Chandler replied that:

…this is still a matter at fact. And because the jury is our factfinders, we need to educate them on what the law is on an odor of marijuana and that it could have been legal….I feel that it is extremely relevant.

The State countered that even if hemp was located in Chandler’s vehicle,

…it doesn't make the detention unlawful. And, again, although they attempted to detain the defendant, he stepped on the gas and left. They weren't able to detain him. But even if we assume the facts the defense's way and it wasn't really marijuana, it was CBD or it was hemp or what have you, it's not relevant.

After these arguments, the trial court sustained the State’s objection “based on what the charge is….”

On appeal, Chandler contends that the State proposed an incorrect assumption at trial that Chandler had a motive to evade arrest because he had marijuana in his vehicle. The State disputes this. Regardless, Chandler was

5

charged with evading arrest or detention, not possession of marijuana. Motive is not an element of evading arrest or detention. See TEX. PENAL CODE § 38.04(a). Thus, educating the jury on the law regarding hemp in order to dispel an alleged motive to flee is not a proper area of inquiry on voir dire.

Accordingly, the trial court did not abuse its discretion in limiting Chandler’s ability to conduct voir dire about the legal difference between hemp and marijuana. Chandler’s third issue is overruled. CONCLUSION Having overruled each of Chandler’s issues, we affirm the trial court's judgment.

LEE HARRIS

Justice

OPINION DELIVERED and FILED: August 20, 2026 Before Chief Justice Johnson, Justice Smith, and Justice Harris Affirmed Do Not Publish CR25