James R. Hiatt v. State

CourtCourt of Appeals of Texas
DecidedApril 28, 2010
Docket04-09-00270-CR
StatusPublished

This text of James R. Hiatt v. State (James R. Hiatt 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.

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James R. Hiatt v. State, (Tex. Ct. App. 2010).

Opinion

i i i i i i

OPINION

No. 04-09-00270-CR

James R. HIATT, Appellant

v.

The STATE of Texas, Appellee

From the 144th Judicial District Court, Bexar County, Texas Trial Court No. 06-CR-2741 Honorable Catherine Torres-Stahl, Judge Presiding

Opinion by: Catherine Stone, Chief Justice

Sitting: Catherine Stone, Chief Justice Sandee Bryan Marion, Justice Rebecca Simmons, Justice

Delivered and Filed: April 28, 2010

AFFIRMED

James Hiatt was charged with committing the offenses of indecency with a child and

aggravated sexual assault of a child. A jury found Hiatt guilty of five counts of indecency with a

child and four counts of aggravated sexual assault of a child. The jury assessed Hiatt’s punishment

at 20 years confinement for each count of indecency with a child and 60 years confinement for each

count of aggravated sexual assault of a child. Hiatt appeals his convictions, raising twenty-nine

issues on appeal. We affirm the trial court’s judgment. 04-09-00270-CR

BACKGROUND

The complainant, D.H., joined the Boy Scouts when he was around 12 or 13 years old. Hiatt

was D.H.’s assistant Scout Master. D.H.’s mother permitted D.H. to spend about every other

weekend at Hiatt’s home from 2004 until November 2005. D.H. would go to Hiatt’s house on Friday

and return home on Sunday. Over the course of D.H.’s visits, Hiatt allegedly began engaging in

sexual acts with D.H. These acts included masturbation and anal intercourse.

A neighbor reported Hiatt to the authorities in November 2005, after she observed him

engage in an inappropriate act with D.H. Hiatt was subsequently arrested and indicted for the

offenses of indecency with a child and aggravated sexual assault of a child. He pleaded not guilty

and proceeded to a jury trial. The jury found Hiatt guilty of five counts of indecency with a child and

four counts of aggravated sexual assault of a child, but acquitted Hiatt of one count of indecency

with a child. Hiatt was sentenced to 20 years confinement for each count of indecency with a child

by contact and 60 years confinement for each count of aggravated sexual assault of a child, with the

sentences to run concurrently.

Hiatt filed a motion for new trial following his convictions, which was overruled by operation

of law. Hiatt’s counsel failed to timely pursue his appeal, and the Court of Criminal Appeals granted

him habeas corpus relief in the form of an out-of-time appeal. Hiatt filed a second motion for new

trial and perfected an appeal following the Court of Criminal Appeals’s decision. Hiatt’s second

motion for new trial was subsequently overruled by operation of law.

SUFFICIENCY OF THE EVIDENCE

In two issues, Hiatt challenges the legal and factual sufficiency of the evidence to support his

convictions. Hiatt claims the evidence is legally and factually insufficient to support his conviction

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for aggravated sexual assault of a child based on acts allegedly occurring on or about August 20,

2005. He also challenges the factual sufficiency of the evidence to support any of his other

convictions.

When reviewing the legal sufficiency of the evidence, we consider whether, after viewing

the evidence in the light most favorable to the prosecution, any rational trier of fact could have found

the essential elements of the offense beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307,

319 (1979); Clayton v. State, 235 S.W.3d 772, 778 (Tex. Crim. App. 2007). “This standard accounts

for the factfinder’s duty ‘to resolve conflicts in the testimony, to weigh the evidence, and to draw

reasonable inferences from basic facts to ultimate facts.’” Clayton, 235 S.W.3d at 778 (quoting

Jackson, 443 U.S. at 319). Thus, “in analyzing legal sufficiency, we ‘determine whether the

necessary inferences are reasonable based upon the combined and cumulative force of all the

evidence when viewed in the light most favorable to the verdict.’” Id.

In reviewing the factual sufficiency of the evidence, we look at the evidence in a neutral light,

giving almost complete deference to the jury’s determinations of credibility. Lancon v. State, 253

S.W.3d 699, 705 (Tex. Crim. App. 2008). We reverse only if the evidence supporting the verdict

is so weak that the verdict seems clearly wrong and manifestly unjust or if the evidence supporting

the verdict is outweighed by the great weight and preponderance of the available evidence. Watson

v. State, 204 S.W.3d 404, 414-15 (Tex. Crim. App. 2006). We may not reweigh the evidence or

substitute our judgment for that of the jury under a factual sufficiency review. Id. at 417; King v.

State, 29 S.W.3d 556, 563 (Tex. Crim. App. 2000).

Counts one through four of the indictment allege Hiatt committed the offense of aggravated

sexual assault of a child. A person commits the offense of aggravated sexual assault of a child if,

-3- 04-09-00270-CR

with a child younger than fourteen years, the person intentionally or knowingly: (1) causes the

penetration of the anus or sexual organ of the child by any means; or (2) causes the sexual organ of

the child to contact or penetrate the mouth, anus, or sexual organ of another person, including the

actor. TEX . PENAL CODE ANN . § 22.021(a)(1)(B), (2)(B) (Vernon Supp. 2009). Counts seven

through ten of the indictment allege Hiatt committed indecency with a child by contact. A person

commits the offense of indecency with a child by contact if, with a child younger than seventeen

years and not the person’s spouse, the person engages in sexual contact with the child or causes the

child to engage in sexual contact. Id. § 21.11(a)(1) (Vernon 2003).1 “Sexual contact” includes the

following acts, if committed with the intent to arouse or gratify the sexual desire of any person: (1)

any touching by a person, including touching through clothing, of the anus, breast, or any part of the

genitals of a child; or (2) any touching of any part of the body of a child, including touching through

clothing, with the anus, breast, or any part of the genitals of a person. Id. § 21.11(c).

Counts three and four of the indictment accuse Hiatt of committing aggravated sexual assault

of a child by intentionally and knowingly causing D.H.’s sexual organ to contact and penetrate his

anus and by penetrating D.H.’s anus with his finger on or about August 20, 2005. Hiatt claims the

evidence is insufficient to support his convictions for these offenses because D.H. failed to provide

precise details about the alleged abuse that occurred around August 2005. We disagree with Hiatt’s

contention.

1 … Texas Penal Code section 21.11 was amended after Hiatt’s trial. See Act of May 30, 2009, 81st Leg., R.S., ch. 260, § 1, 2009 Tex. Sess. Law Serv. 709, 709 (amended 2009) (current version at T EX . P EN AL C O D E A N N . § 21.11 (Vernon Supp. 2009).

-4- 04-09-00270-CR

The record shows D.H. testified he was younger than fourteen years of age when he and Hiatt

engaged in various sexual acts together. D.H. stated he and Hiatt regularly masturbated each other

to the point of ejaculation from 2004 until November 2005. D.H. testified he visited Hiatt “pretty

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