James Haught v. the State of Texas

Court of Appeals of Texas·Decided September 16, 2021·No. 02-20-00054-CR·Published

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________

No. 02-20-00054-CR ___________________________

JAMES HAUGHT, Appellant

V.

THE STATE OF TEXAS

On Appeal from County Criminal Court No. 5 Denton County, Texas Trial Court No. F18-3232-158

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

Appellant James Haught was convicted of felony driving while intoxicated, and

his punishment was enhanced under Texas’s habitual-offender statute based on two

prior felony convictions. Haught now claims that his trial counsel provided ineffective

assistance by allegedly misrepresenting the applicable punishment range. But the record

reveals that counsel’s alleged misrepresentation was not a misrepresentation at all; it was

a strategic challenge to one of the punishment enhancements. And even if Haught’s

counsel had misrepresented the applicable punishment range, Haught has not

explained—much less carried his burden to prove—how he was prejudiced by the

alleged misrepresentation. For these two independently sufficient reasons, we will

overrule Haught’s sole issue and affirm his conviction.

I. Background

Haught was found guilty of third-degree-felony driving while intoxicated (DWI).1

Tex. Penal Code Ann. §§ 49.04(a), 49.09(b)(2). Although the standard punishment for

this offense is 2 to 10 years’ confinement, the State sought to enhance Haught’s

punishment under the relevant habitual-offender statute. Id. §§ 12.34, 12.42.

Under the habitual-offender statute, Haught’s punishment range would increase

to 2 to 20 years’ confinement if the State proved that he had one prior felony conviction.

1 Haught’s offense was a third-degree felony because he had two prior convictions for driving while intoxicated. Tex. Penal Code Ann. § 49.09(b)(2).

2 See id. §§ 12.33(a), 12.42(a). And if the State proved that Haught had a second prior

felony conviction for “an offense that occurred subsequent to the first previous

conviction having become final,” then the punishment range would increase to 25 to

99 years or life. See id. § 12.42(d). The State pursued the latter option; it sought to

enhance Haught’s punishment based on two prior felony convictions: (1) a 1996

conviction for burglary and (2) a 2007 conviction for a methamphetamine-related

conspiracy.

At the punishment stage of trial, Haught conceded that the State had proved he

had at least one prior felony conviction—the 1996 burglary conviction.2 But Haught

argued that the State could not prove that the conspiracy underlying his second felony

conviction began “subsequent to the first [1996] . . . conviction[’s] having become

final.” Id.. Haught’s trial counsel emphasized that the 2007 judgment listed an end date

for the conspiracy but did not indicate when he began conspiring. 3 Haught’s counsel

2 Although Haught ultimately conceded that the State had proven his 1996 felony conviction, he pleaded not true to the punishment enhancements. 3 This allegedly ambiguous 2007 judgment was the primary evidence the State relied upon to prove the date that Haught’s conspiracy occurred. Haught objected to the admissibility of the 2007 judgment; in addition to the sequence-related argument discussed above, he claimed (1) the identifiers on the judgment were insufficient to prove that the individual convicted was him, (2) the 2007 judgment was not final because it did not show that he had completed his probation for conspiracy, and (3) the judgment did not demonstrate that he was properly admonished and waived his right to a jury trial. The trial court overruled these objections, and Haught does not raise them on appeal.

3 argued that because Haught’s conspiracy could have started before his 1996 burglary

conviction became final, the State could not use both felony convictions to enhance his

punishment range for the felony DWI; it could only use one. Following this logic,

Haught’s trial counsel contended that the applicable punishment range was 2 to 20

years. Counsel previewed this argument before the punishment phase began, telling

the trial court on the record: “[T]he range of punishment is 2 to 20. They [i.e., the State]

might argue it’s something different, but I think there’s an argument as to what it is.”

The State, of course, did argue that the punishment range was something

different; it claimed that the 2007 judgment was sufficient to prove that Haught’s

conspiracy offense occurred after his burglary conviction became final, making the

applicable punishment range for his felony DWI 25 to 99 years. The trial court agreed

with the State. It found both enhancement paragraphs true and sentenced Haught to

25 years’ confinement.

Haught now appeals, alleging ineffective assistance of counsel.

II. Standard of Review

The Sixth Amendment guarantees a criminal defendant the effective assistance

of counsel. Ex parte Scott, 541 S.W.3d 104, 114 (Tex. Crim. App. 2017); see U.S. Const.

amend. VI. To establish an ineffective-assistance claim under the Sixth Amendment,

an appellant must prove by a preponderance of the evidence that (1) his counsel’s

representation was deficient and (2) the deficiency prejudiced his defense. Strickland v.

4 Washington, 466 U.S. 668, 687, 104 S. Ct. 2052, 2064 (1984); Nava v. State, 415 S.W.3d

289, 307 (Tex. Crim. App. 2013).

The first Strickland prong—deficient performance—requires an appellant to

prove that “counsel’s representation fell below an objective standard of reasonableness

based upon prevailing norms.” Jackson v. State, 973 S.W.2d 954, 956 (Tex. Crim. App.

1998). Our review of counsel’s representation is “highly deferential”; we indulge a

“strong presumption” that counsel provided adequate assistance. Thompson v. State, 9

S.W.3d 808, 813–14 (Tex. Crim. App. 1999). If the record is silent as to the attorney’s

reasons, we must presume that the challenged conduct “constituted sound trial

strategy” unless the conduct was “so outrageous that no competent attorney would

have engaged in it.” Johnson v. State, 624 S.W.3d 579, 586 (Tex. Crim. App. 2021)

(quoting Goodspeed v. State, 187 S.W.3d 390, 392 (Tex. Crim. App. 2005)); Prine v. State,

537 S.W.3d 113, 117 (Tex. Crim. App. 2017) (same).

Strickland’s second prong—prejudice—requires an appellant to prove that

counsel’s errors were so serious that they deprived him of a fair trial. Strickland, 466

U.S. at 687, 104 S. Ct. at 2064. In other words, an appellant must show a reasonable

probability that the proceeding would have turned out differently without the deficient

performance.4 Id. at 694, 104 S. Ct. at 2068; Nava, 415 S.W.3d at 308.

4 A “reasonable probability” is a probability sufficient to undermine confidence in the outcome. Strickland, 466 U.S. at 694, 104 S. Ct. at 2068; Nava, 415 S.W.3d at 308.

5 For an appellant to prevail on his ineffective-assistance claim, the record must

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