James Hail Benson v. State

CourtCourt of Appeals of Texas
DecidedApril 5, 2007
Docket01-05-00063-CR
StatusPublished

This text of James Hail Benson v. State (James Hail Benson 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 Hail Benson v. State, (Tex. Ct. App. 2007).

Opinion

Opinion issued April 5, 2007





In The

Court of Appeals

For The

First District of Texas



NO. 01-05-00063-CR



JAMES HAIL BENSON, Appellant



V.



THE STATE OF TEXAS, Appellee



On Appeal from the 208th District Court

Harris County, Texas

Trial Court Cause No. 818465



DISSENTING OPINION ON EN BANC

The majority misstates the relief actually requested by appellant, James Hail Benson, misconstrues the statement that he made in his pro se notice of appeal, and then, in violation of the doctrine of stare decisis, proceeds to use this case to overrule and "abandon" the well-reasoned and six-year-old precedent of Jack v. State, 42 S.W.3d 291 (Tex. App.--Houston [1st Dist.] 2001, order) (Jack I). In so doing, the majority establishes in Texas jurisprudence a classic "catch-22," (1) which violates the Due Process Clause of the United States Constitution and the Due Course of Law provision of the Texas Constitution. See U.S. Const. amend. XIV; Tex. Const. art. I, § 19. Accordingly, I respectfully dissent.

The Problem: A Legal Catch-22

Texas Courts have long noted that, in reviewing a criminal defendant's contention that he received ineffective assistance of counsel at trial, we look to the totality of the trial representation to determine the effectiveness of counsel, indulging a strong presumption that trial counsel's performance falls within the wide range of reasonable professional assistance or trial strategy. Thompson v. State, 9 S.W.3d 808, 813 (Tex. Crim. App. 1999). A claim of ineffective assistance must be firmly supported in the record, see id., and it can be extremely difficult to show that trial counsel's performance was deficient when there is no proper evidentiary record developed at a hearing on a motion for new trial. See Johnson v. State, 176 S.W.3d 74, 79 (Tex. App.--Houston [1st Dist.] 2004, pet. ref'd); Sudds v. State, 140 S.W.3d 813, 819 (Tex. App.--Houston [14th Dist.] 2004, no pet.) (citing Bone v. State, 77 S.W.3d 828, 833 (Tex. Crim. App. 2002)).

This aptly demonstrates what the Texas Court of Criminal Appeals has long recognized, i.e., "[w]ithout doubt the hearing on a motion for new trial is a critical stage of the proceedings. It is the only opportunity to present to the trial court certain matters that may warrant a new trial, and to make a record on those matters for appellate review." Trevino v. State, 565 S.W.2d 938, 940 (Tex. Crim. App. 1978) (quoted in Jack I, 42 S.W.3d at 292) (emphasis added). Texas courts have consistently held that "the time period for filing a motion for new trial is a critical stage of a criminal proceeding in which defendants are entitled to assistance of counsel." Jack I, 42 S.W.3d at 292 (citations omitted). Moreover, as acknowledged by the majority, "[w]hen a defendant is deprived of effective assistance of counsel during the period for filing a motion for new trial, the remedy is to reset the appellate time limits." See Ward v. State, 740 S.W.2d 794, 800 (Tex. Crim. App. 1987); see also Jack v. State, 64 S.W.3d 694, 697 (Tex. App.--Houston [1st Dist.] 2002, order) (Jack II).

Accordingly, the Texas Court of Criminal Appeals has indicated that trial courts should appoint appellate counsel "at the same time that a defendant gives notice of appeal to ensure that a defendant's post trial rights and options are fully protected." Jack v. State, 149 S.W.3d 119, 122 n.4 (Tex. Crim. App. 2004) (Jack III). Under Texas Rule of Appellate Procedure 25.2(a)(2), a trial court should "enter the certification of appeal at the time of sentencing, and it is at that time, if an indigent defendant has the right to appeal and wishes to do so, the trial court will appoint counsel." Id. (citing Tex. R. App. P. 25.2(a)(2)).

However, a serious problem arises when, as here, a case "sometimes slip[s] through the crack and, although notice of appeal was timely filed, appointment of appellate counsel was not made until long after" the date that the notice of appeal was filed. Jack III, 149 S.W.3d at 122 n.4. In such cases, if the defendant wants to appeal his conviction on the ground that his trial counsel was ineffective, but the trial court does not appoint appellant counsel until after the deadline has past for filing a motion for new trial, the defendant will be precluded from presenting a meaningful appeal. He will not be able to present a proper evidentiary record developed at a hearing on a motion for new trial--all because of an administrative error made by the trial court. He will be caught up in a legal catch-22. It is this problem that we effectively addressed in Jack I and Jack II.

Jack I & Jack II

In Jack I, the defendant's court-appointed appellate counsel filed a motion to abate the appeal and for leave to file an out-of-time motion for new trial. 42 S.W.3d at 292. She asserted that because the trial court appointed appellate counsel more than 30 days after the defendant was sentenced, the defendant was unrepresented by counsel during the 30-day period for filing a motion for new trial. Id. She also asserted that had she been timely appointed, she would have filed a motion for new trial, alleging ineffective assistance of trial counsel because trial counsel did not subpoena material witnesses. Id. Although we noted that everything in the record indicated that the defendant was not assisted by counsel during the 30-day critical stage for filing a motion for new trial, we recognized that the Texas Court of Criminal Appeals has previously held that "[w]hen a motion for new trial is not filed in a case, the rebuttable presumption is that it was considered by the appellant and rejected." Id. at 293 (quoting Smith v. State, 17 S.W.3d 660, 662 (Tex. Crim. App. 2000)); Oldham v. State, 977 S.W.2d 354, 363 (Tex.

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