James Michael Sotelo v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 12, 2025
Docket01-24-00567-CR
StatusPublished

This text of James Michael Sotelo v. the State of Texas (James Michael Sotelo v. the State of Texas) 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 Michael Sotelo v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

Opinion issued August 12, 2025

In The Court of Appeals For The

First District of Texas ———————————— NOS. 01-24-00562-CR 01-24-00567-CR ——————————— JAMES MICHAEL SOTELO, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 232nd District Court Harris County, Texas Trial Court Cases 1715366 and 1720032

OPINION

The appellant was charged with murder1 and aggravated assault.2 A jury found

him guilty as charged of murder, but acquitted him of aggravated assault and found

1 Trial Court Cause No. 1715366 (No. 01-24-00562-CR). 2 Trial Court Cause No. 1720032 (No. 01-24-00567-CR). him guilty of the lesser-included offense of deadly conduct. The trial court assessed

punishment at forty years’ confinement for the murder and two years’ confinement

for the deadly conduct.

The appellant raises five points of error: One related to an alleged deficiency

in the indictment, one claiming ineffective assistance of counsel, and three related

to court costs. We modify the trial court’s judgment by striking the repetitive court

costs from the judgment in the deadly conduct case and, as modified, affirm.

Background

Because of the nature of the appellant’s claims, it is unnecessary to go into

detail regarding his offenses. For reasons that are unclear, the appellant fired thirteen

shots at his best friend, hitting him in the back eleven times. One bullet went through

a wall and hit the appellant’s brother in the head. The brother survived but the best

friend did not. The appellant testified the shooting was in self-defense.

Indictment Signature

In his first point the appellant complains that his indictments indicate they

were signed by the assistant foreman of the grand jury. The appellant directs us to

Code of Criminal Procedure Article 21.02, which lists among the “requisites of an

indictment” that an indictment “shall be deemed sufficient” if it meets nine criteria,

one of which is that “[i]t shall be signed officially by the foreman of the grand jury.”

Tex. Code Crim. Proc. Art. 21.02(9). The appellant argues the lack of the foreman’s

2 signature means his indictments were insufficient. The appellant argues that without

“sufficient” indictments, the trial court’s jurisdiction was never invoked and the

judgments are void.

The Court of Criminal Appeals has rejected the argument that the lack of the

foreman’s signature renders an indictment invalid. See Riney v. State, 28 S.W.3d

561, 566 (Tex. Crim. App. 2000) (citing article 21.02 and holding the “lack of a

signature is of no consequence in this matter, and is, in fact, not essential to the

validity of an indictment”); Tatmon v. State, 815 S.W.2d 588, 590 (Tex. Crim. App.

1991) (holding trial court did not abuse discretion in denying motion to quash based

on lack of foreman’s signature, reasoning that “the absence of [foreman’s] signature

did not adversely affect the validity of the indictment”); Owens v. State, 540 S.W.2d

324, 325 (Tex. Crim. App. 1976) (“The failure of the foreman of the grand jury to

sign the indictment does not vitiate that instrument. It is permissible therefore for

another grand juror to sign the indictment in his stead.” (citations omitted)).

The appellant criticizes the Court of Criminal Appeals’s reasoning on this

subject. Specifically, he argues that the Court failed to consider statutory change in

1966. But Tatmon addresses the statutory change. See 815 S.W.2d at 589–90. Even

if it did not, we are not free to disregard the direct holdings of the Court of Criminal

Appeals merely because a litigant or even this Court thinks they’re wrong. We

overrule the appellant’s first point.

3 Ineffective Assistance of Counsel

In his second point the appellant claims he received ineffective assistance of

counsel. In the statement of his point the appellant alleges trial counsel “fail[ed] to

know the range of punishment for murder.” In the body of his point, the appellant’s

complaint is that trial counsel requested community supervision during the

punishment phase, but, as the appellant correctly notes, Texas law does not currently

allow trial courts to suspend imposition of sentence for murder convictions. See TEX.

CODE CRIM. PROC. arts. 42A.054(2), 42A.056(3).

Assuming, arguendo, trial counsel’s performance was deficient, the appellant

has failed to direct us to any evidence in the record showing he was harmed by trial

counsel’s request for an illegally lenient sentence. To prevail on a claim of

ineffective assistance, a defendant must prove, by a preponderance of the evidence

not just that counsel’s actions fell below an objective standard of reasonableness, but

that the result of the proceeding would have been different but for counsel’s deficient

performance. Strickland v. Washington, 466 U.S. 668, 687–88, 694 (1984). “If it is

easier to dispose of an ineffectiveness claim on the ground of lack of sufficient

prejudice . . . that course should be followed.” Id. at 697. Ineffective-assistance

claims, including the showing of prejudice, must be firmly founded in the record.

Bone v. State, 77 S.W.3d 828, 835 (Tex. Crim. App. 2002).

4 In his brief, the appellant argues he was harmed because counsel led him to

believe he was probation eligible for murder. As his only support for this, the

appellant points to applications for community supervision he filed before trial. The

State correctly notes, though, that motions for community supervision must be filed

before trial, meaning that at the time the appellant filed his motions it was still a

possibility for the jury to return verdicts that would make the appellant eligible for

community supervision (e.g., acquitting him of murder but convicting of the

aggravated assault, or convicting for a lesser included offense of murder). See TEX.

CODE CRIM. PROC. art. 42A.055(b). Nothing in the record supports the appellant’s

claim that his counsel misinformed him regarding his community supervision

eligibility.

The appellant claims his “belief of eligibility tainted the entire trial for

Appellant,” but he does not cite anything in the record showing how this supposed

belief affected anything. In Swinney v. State, the defendant was eligible for

community supervision only if he chose to have punishment assessed by the jury; he

chose instead to have the trial court assess punishment and, as here, his attorney

requested community supervision although it was not a possible punishment. 663

S.W.3d 87, 89–91 (Tex. Crim. App. 2022). The Court of Criminal Appeals rejected

Swinney’s ineffective-assistance claim, though, because, assuming trial counsel had

given Sweeney incorrect advice before he made his punishment election, Sweeney

5 did not produce evidence showing how, or even whether, the incorrect advice altered

his decision-making. Id. at 92.

Swinney controls here. The record does not show that any incorrect advice

from trial counsel altered any decision the appellant made. There is no record

evidence that the appellant’s decision to go to trial or his election to have the trial

court assess punishment was informed by an erroneous understanding of his

eligibility for probation if convicted.

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Related

Webster v. Fall
266 U.S. 507 (Supreme Court, 1925)
Anders v. California
386 U.S. 738 (Supreme Court, 1967)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Keller v. State
125 S.W.3d 600 (Court of Appeals of Texas, 2003)
Curry v. State
910 S.W.2d 490 (Court of Criminal Appeals of Texas, 1995)
Riney v. State
28 S.W.3d 561 (Court of Criminal Appeals of Texas, 2000)
Breazeale v. State
683 S.W.2d 446 (Court of Criminal Appeals of Texas, 1985)
Bone v. State
77 S.W.3d 828 (Court of Criminal Appeals of Texas, 2002)
Mayer v. State
309 S.W.3d 552 (Court of Criminal Appeals of Texas, 2010)
Light v. State
15 S.W.3d 104 (Court of Criminal Appeals of Texas, 2000)
Owens v. State
540 S.W.2d 324 (Court of Criminal Appeals of Texas, 1976)
Keller, Stephen Philip
146 S.W.3d 677 (Court of Criminal Appeals of Texas, 2004)
Johnson, Manley Dewayne
423 S.W.3d 385 (Court of Criminal Appeals of Texas, 2014)
Peraza v. State
467 S.W.3d 508 (Court of Criminal Appeals of Texas, 2015)
Manley Dewayne Johnson v. State
389 S.W.3d 513 (Court of Appeals of Texas, 2012)
Colby Ray Ballinger v. State
405 S.W.3d 346 (Court of Appeals of Texas, 2013)
London v. State
490 S.W.3d 503 (Court of Criminal Appeals of Texas, 2016)
Salinas, Orlando
523 S.W.3d 103 (Court of Criminal Appeals of Texas, 2017)
Tatmon v. State
815 S.W.2d 588 (Court of Criminal Appeals of Texas, 1991)
London v. State
526 S.W.3d 596 (Court of Appeals of Texas, 2017)

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