James George Guevara v. State

CourtCourt of Appeals of Texas
DecidedDecember 7, 2005
Docket04-00-00340-CR
StatusPublished

This text of James George Guevara v. State (James George Guevara v. State) 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
James George Guevara v. State, (Tex. Ct. App. 2005).

Opinion



No. 04-00-00340-CR


James GUEVARA,

Appellant


v.


The STATE of Texas,

Appellee


From the 226th Judicial District Court, Bexar County, Texas

Trial Court No. 99-CR-1818B

Honorable Sid L. Harle, Judge Presiding


En Banc Opinion on Remand

Opinion by:    Karen Angelini, Justice

Sitting:            Alma L. López, Chief Justice

Catherine Stone, Justice

Sarah B. Duncan, Justice

Karen Angelini, Justice

Sandee Bryan Marion, Justice

Phylis J. Speedlin, Justice

Rebecca Simmons, Justice

Delivered and Filed:   December 7, 2005


REVERSED AND REMANDED


            A jury found James Guevara guilty as a party to the murder of his wife, Velia Guevara, and sentenced him to life in prison and a $10,000 fine. On original submission, Guevara complained of the sufficiency of the evidence, error in the jury charge, prosecutorial misconduct, and ineffective assistance of counsel. In an opinion and judgment dated December 26, 2001, we affirmed the trial court’s judgment. Guevara filed motions for rehearing and for reconsideration by the en banc court. On January 31, 2003, this court, in an en banc opinion, granted Guevara’s motions, withdrew our December 26th opinion and judgment, and issued an opinion and judgment in which we reversed the trial court’s judgment and remanded for a new trial. In our January 2003 opinion, a majority of the en banc court held that the evidence was legally and factually sufficient to support the verdict. However, relying on this court’s opinion in Bagheri v. State, 87 S.W.3d 657 (Tex. App.—San Antonio 2002), aff’d, 119 S.W.3d 755 (Tex. Crim. App. 2003) and on Texas Rule of Appellate Procedure 44.2(b), we reversed and remanded for a new trial after concluding that the error contained in the jury charge affected Guevara’s substantial rights.

            Both Guevara and the State petitioned the Court of Criminal Appeals for discretionary review. Guevara challenged our holding that the evidence was legally sufficient to support the verdict, and the State challenged our holding with respect to charge error. The Court of Criminal Appeals determined the evidence was legally sufficient to support the verdict. See Guevara v. State, 152 S.W.3d 45, 52 (Tex. Crim. App. 2004). Although the Court of Criminal Appeals refused to “address whether the inclusion of the legal-duty theory in the charge was error,” id. at 52, n.28, the Court nevertheless determined this court applied an incorrect standard of review for charge error, and remanded the cause to this court to conduct a harm analysis under Texas Code of Criminal Procedure article 36.19.

STANDARD OF REVIEWArticle 36.19 provides that “[w]henever it appears by the record in any criminal action upon appeal that any requirement of Articles 36.14, 36.15, 36.16, 36.17 and 36.18 has been disregarded, the judgment shall not be reversed unless the error appearing from the record was calculated to injure the rights of defendant, or unless it appears from the record that the defendant has not had a fair and impartial trial.” Tex. Code Crim. Proc. Ann. § 36.19 (Vernon 1981). When, as here, no objection is made at trial to charge error, a defendant on appeal must show that the error was “so egregious and created such harm that he ‘has not had a fair and impartial trial.’” Almanza v. State, 686 S.W.2d 157, 171 (Tex. Crim. App. 1984). Under the Almanza standard, the record must show that a defendant has suffered actual, rather than merely theoretical, harm from jury charge error. Dickey v. State, 22 S.W.3d 490, 492 (Tex. Crim. App. 1999). Errors that result in egregious harm are those that affect “the very basis of the case,” “deprive the defendant of a valuable right,” or “vitally affect a defensive theory.’” Ngo v. State, No. PD-0504-04, 2005 WL 600353, at *6 (Tex. Crim. App. Mar. 16, 2005); Hutch v. State, 922 S.W.2d 166, 171 (Tex. Crim. App. 1996). On appeal, we assess the actual degree of harm “in light of the entire jury charge, the state of the evidence, including the contested issues and weight of probative evidence, the argument of counsel and any other relevant information revealed by the record of the trial as a whole.” Almanza, 686 S.W.2d at 171.

CHARGE ERROR

            A trial court must fully instruct the jury on the law applicable to the case and apply that law to the facts adduced at trial. Gray v. State, 152 S.W.3d 125, 127 (Tex. Crim. App. 2004); Tex. Code Crim. Proc. Ann. art. 36.14 (Vernon Supp. 2004-05). “This is because “[t]he jury must be instructed ‘under what circumstances they should convict, or under what circumstances they should acquit’.” Gray, 152 S.W.3d at 127-28 (quoting Ex parte Chandler, 719 S.W.2d 602, 606 (Tex. Crim. App. 1986)). “Jury charges which fail to apply the law to the facts adduced at trial are erroneous.” Id. at 128.

            The jury charge here contained two theories under which the jury could find Guevara criminally responsible for his wife’s murder: (1) that Guevara solicited, encouraged, directed, aided, or attempted to aid another person in committing the offense (“the aiding theory”), or (2) that Guevara did not make a reasonable effort to prevent the commission of the offense when he had a legal duty to do so (“the legal duty theory”). The abstract portion of the charge informed the jury that:

            A person is criminally responsible as a party to an offense if the offense is committed by his own conduct, by the conduct of another for which he is criminally responsible, or both. Each party to an offense may be charged with commission of the offense.

            Mere presence alone will not make a person a party to an offense. A person is criminally responsible for an offense committed by the conduct of another if acting with intent to promote or assist the commission of the offense, he solicits, encourages, directs, aids, or attempts to aid the other person to commit the offense; or having a legal duty to prevent commission of the offense and acting with intent to promote or assist its commission, he fails to make a reasonable effort to prevent commission of the offense. [Emphasis added.]

The charge did not define “legal duty” for the jury. The charge did not set forth the elements of any legal duty Guevara may have owed to Velia, nor did it instruct the jury on when such a duty attaches. See Kavali v. State, No. 05-01-00835-CR, 2002 WL 31445280, *4 (Tex. App.—Dallas Nov. 4, 2002, pet.

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