James Michael Chin v. State

Court of Appeals of Texas·Decided December 31, 2013·No. 04-13-00242-CR·Published

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION Nos. 04-13-00242-CR & 04-13-00243-CR

James Michael CHIN, Appellant

v. The STATE of The STATE of Texas, Appellee

From the 290th Judicial District Court, Bexar County, Texas Trial Court Nos. 2012CR5328 & 2011CR7140 Honorable Melisa Skinner, Judge Presiding

Opinion by: Catherine Stone, Chief Justice

Sitting: Catherine Stone, Chief Justice Marialyn Barnard, Justice Patricia O. Alvarez, Justice

Delivered and Filed: December 31, 2013

AFFIRMED

James Michael Chin was convicted by a jury of aggravated sexual assault of a child and

indecency with a child. The victims were Chin’s step-daughters. On appeal, Chin asserts: (1) the

prosecution failed to disclose a favorable email communication to him; (2) the trial court erred in

excluding the email as not properly authenticated; (3) trial counsel rendered ineffective assistance

of counsel; and (4) testimony regarding a medical report was admitted into evidence in violation

of the Confrontation Clause. We overrule Chin’s issues and affirm the trial court’s judgments. 04-13-00242-CR & 04-13-00243-CR

BRADY CLAIM

In his first issue, Chin contends the prosecution failed to disclose an email from the victims’

mother in which the victims’ mother admitted that one of the victims had lied about the sexual

abuse. Chin asserts that the State’s failure to disclose the email was in violation of Brady v.

Maryland, 373 U.S. 83 (1963).

In Brady, the United States Supreme Court held “‘that the suppression by the prosecution

of evidence favorable to an accused upon request violates due process where the evidence is

material either to guilt or to punishment, irrespective of the good faith or bad faith of the

prosecution.’” Pena v. State, 353 S.W.3d 797, 809 (Tex. Crim. App. 2011) (quoting Brady, 373

U.S. at 87). “The scenarios to which Brady applies ‘involve[ ] the discovery, after trial of

information which had been known to the prosecution but unknown to the defense.’” Id. at 810

(quoting United States v. Agurs, 427 U.S. 97, 103 (1976)). Consequently, the State does not have

a duty to disclose if the defendant is actually aware of the exculpatory evidence. Id.

In this case, the email which Chin asserts was not disclosed was an email allegedly sent to

him and in his possession. In fact, Chin sought to introduce the email into evidence at trial. Even

if we were to assume that the prosecution was aware of the email, 1 no disclosure was required

because Chin was actually aware of it. See id.

In his brief and in his reply brief, Chin alternates between complaining about the specific

email he sought to introduce at trial and the collection of emails between Angela and Chin after

the outcry. Although Chin contends it would be “unbelievable” that the State was unaware of

these emails, nothing in the record establishes knowledge on the part of the State. Moreover, just

as Brady does not apply to evidence of which the defendant is actually aware, Brady also does not

1 During her testimony, the victims’ mother denied ever having sent the email.

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apply when the defendant “could have accessed [the evidence] from other sources.” Id. at 810.

Stated differently, “[a]n accused may not require the prosecution to obtain evidence for him that

is equally available to the accused and the prosecution.” Flores v. State, 940 S.W.3d 189, 191

(Tex. App.—San Antonio 1996, no pet.). Since the emails in question were sent to Chin, it stands

to reason that they were equally available to him and that he could have accessed them from other

sources. Accordingly, Chin’s first issue is overruled.

EXCLUSION OF EMAIL

In his second issue, Chin contends the trial court erred in excluding the email from

evidence.

“Evidence has no relevance if it is not authentically what its proponent claims it to be.”

Tienda v. State, 358 S.W.3d 633, 638 (Tex. Crim. App. 2012). “Rule 901(a) of the Rules of

Evidence defines authentication as a ‘condition precedent’ to admissibility of evidence that

requires the proponent to make a threshold showing that would be ‘sufficient to support a finding

that the matter in question is what its proponent claims.’” Id. (quoting TEX. R. EVID. 901(a)). In

determining whether the proponent has made a sufficient threshold showing, the trial court must

decide “whether the proponent of the evidence has supplied facts that are sufficient to support a

reasonable jury determination that the evidence he has proffered is authentic.” Id. We review the

trial court’s ruling on this preliminary question of admissibility under an abuse of discretion

standard. Id.

Electronic evidence may be authenticated in a number of different ways. Id. Printouts of

emails have “been admitted into evidence when found to be sufficiently linked to the purported

author so as to justify submission to the jury for its ultimate determination of authenticity.” Id. at

639. With regard to printouts of emails, the Texas Court of Criminal Appeals has instructed “[t]hat

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an email on its face purports to come from a certain person’s email address” is typically not

sufficient to support a finding of authenticity without additional links. Id. at 641-42 & n. 36.

In this case, the victims’ mother denied sending Chin the email in question, and the only

link between the victims’ mother and the email was the email address. When discussing the

admissibility of the evidence at trial, the trial court determined that Chin had not met his threshold

burden, noting:

Because it looks to me like it’s very possible that somebody xeroxed one thing on top of another. And you cannot say that’s an original. And she’s denying that she ever did it. So unless you have some record that’s going to be more authentic than that, then I’m not allowing that. I can go back there right now and take my email and cut off the to and the from and then place it over another statement and xerox it. And that doesn’t mean that that’s an authentic e-mail.

Because the only link between the email in question and the victims’ mother was the email

purporting on its face to have been sent from her email address, the trial court did not abuse its

discretion in excluding the email from evidence, and Chin’s second issue is overruled,

INEFFECTIVE ASSISTANCE OF COUNSEL

In his third issue, Chin contends trial counsel was ineffective in representing him.

Primarily, Chin focuses on trial counsel’s failure to pursue additional evidence, including expert

testimony, to lay a proper predicate for the introduction of the email addressed in his second issue.

Chin also points to trial counsel’s failure to file additional pre-trial discovery motions to determine

the substance of the evidence the State would introduce at trial.

To prevail on a claim of ineffective assistance of counsel, an appellant must prove two

elements by a preponderance of the evidence: (1) deficient performance of trial counsel; and (2)

harm resulting from that deficiency sufficient to undermine confidence in the outcome of the trial.

Strickland v.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Agurs
427 U.S. 97 (Supreme Court, 1976)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Rylander v. State
101 S.W.3d 107 (Court of Criminal Appeals of Texas, 2003)
Berkley v. State
298 S.W.3d 712 (Court of Appeals of Texas, 2010)
Bone v. State
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Goodspeed v. State
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Thompson v. State
9 S.W.3d 808 (Court of Criminal Appeals of Texas, 1999)
Garcia v. State
57 S.W.3d 436 (Court of Criminal Appeals of Texas, 2001)
Pena, Jose Luis
353 S.W.3d 797 (Court of Criminal Appeals of Texas, 2011)
Tienda, Ronnie Jr.
358 S.W.3d 633 (Court of Criminal Appeals of Texas, 2012)
Lahood, Ex Parte Michael George
401 S.W.3d 45 (Court of Criminal Appeals of Texas, 2013)
Moore, Ex Parte Darron T.
395 S.W.3d 152 (Court of Criminal Appeals of Texas, 2013)