James Ray Demps v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 4, 2024
Docket09-22-00352-CR
StatusPublished

This text of James Ray Demps v. the State of Texas (James Ray Demps 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 Ray Demps v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-22-00352-CR __________________

JAMES RAY DEMPS, Appellant

V.

THE STATE OF TEXAS, Appellee

__________________________________________________________________

On Appeal from the 9th District Court Montgomery County, Texas Trial Cause No. 21-10-13928-CR __________________________________________________________________

MEMORANDUM OPINION

A jury found James Ray Demps (“Appellant” or “Demps”) guilty of

aggravated sexual assault of a child younger than six years of age and assessed

punishment of forty-five years of confinement. In three appellate issues, Demps

argues the trial court erred in (1) allowing a support person to accompany the child

witness during her testimony in front of the jury; (2) failing to instruct the jury that

Demps was not eligible for parole and to not consider the application of parole to

him; and (3) failing to give a curative instruction to the jury when the trial court

1 received a jury note during deliberations about parole. We affirm the trial court’s

judgment.

Background

Because Demps does not challenge the sufficiency of the evidence to support

this conviction, only a brief recitation of the facts is necessary. See King v. State,

953 S.W.2d 266, 267 (Tex. Crim. App. 1997); see also Tex. R. App. P. 47.1. A grand

jury indicted Demps for aggravated sexual assault of L.S.1 (“Linda”), a child under

six years of age, and the indictment included an enhancement allegation for a prior

felony conviction. See Tex. Penal Code Ann. § 22.021(a)(2)(B), (f)(1). According to

the indictment, on or about November 23, 2020, Demps “intentionally or knowingly

cause[d] [his] sexual organ to contact or penetrate the mouth of [Linda], a child who

was then and there younger than 6 years of age[.]” Demps pleaded “not guilty.”

During the guilt-innocence phase of the trial, the jury heard Linda’s Mother testify

that, while Demps was living with them when Linda was five years old, Linda

reported to her, after Linda had been out of school and on Thanksgiving break in

2020, that Demps made her touch his “private part” and put his “private part” in

Linda’s mouth. The jury also heard Linda, who was seven years old at the time of

1 We use pseudonyms to refer to the alleged victim and family members. See Tex. Const. art. I, § 30(a)(1) (granting crime victims “the right to be treated with fairness and with respect for the victim’s dignity and privacy throughout the criminal justice process[.]”). 2 trial, testify about the alleged assaults, and the jury heard from other trial witnesses

including law enforcement and a nurse. The jury found Demps guilty of the offense.

Appellant pleaded “not true” to the enhancement allegation. During the punishment

phase of the trial, the jury heard evidence that Demps had two misdemeanor

convictions in 2011 for criminal mischief and theft and a 2018 felony conviction of

engaging in organized criminal activity. The jury heard testimony that while Demps

was on parole for the 2018 conviction, he moved in with Linda’s mother. The jury

also heard evidence that after he was picked up on a warrant for this case, he exposed

his penis to a jail nurse bringing him medication and masturbated in front of a female

inmate that was returning from court. After hearing punishment evidence, the jury

assessed Demps’s punishment at forty-five years of incarceration.2 The trial court

sentenced Demps in accordance with the jury’s verdict. Demps timely appealed.

2 Aggravated sexual assault of a child, a first-degree felony, carries an applicable punishment range of five to ninety-nine years or life in prison. Tex. Penal Code Ann. §§ 12.32(a), 22.021(a)(1)(B), (a)(2)(B), (e). Because Linda was under the age of six at the time of the commission of the offense, Demps’s punishment was enhanced by statute to a minimum of twenty-five years of confinement. See Tex. Penal Code Ann. § 22.021(f)(1). A finding of true to the enhancement allegation would have raised Demps’s minimum sentence from five years to fifteen years. See Tex. Penal Code Ann. §§ 12.42(c)(1), 71.02(a)(1). Because the enhancement under section 22.021(f)(1) resulted in a minimum sentence greater than the minimum sentence for the enhancement paragraph alleged in the indictment, the trial court announced that “we received no finding” on the enhancement paragraph of the indictment “because it had no effect.” 3 Support Person Under Article 38.074

In his first issue, Demps argues the trial court erred in allowing a support

person to accompany Linda during her testimony in front of the jury. Section 3 of

Article 38.074 of the Texas Code of Criminal Procedure provides, in relevant part:

(b) On the motion of any party, . . . the court shall allow the child to have a toy, blanket, or similar comforting item in the child’s possession while testifying or allow a support person to be present in close proximity to the child during the child’s testimony if the court finds by a preponderance of the evidence that: (1) the child cannot reliably testify without the possession of the item or presence of the support person, as applicable; and (2) granting the motion is not likely to prejudice the trier of fact in evaluating the child’s testimony. (c) A support person who is present during a child’s testimony may not: (1) obscure the child from the view of the defendant or the trier of fact; (2) provide the child with an answer to any question asked of the child; or (3) assist or influence the testimony of the child. (d) The court may set any other conditions and limitations on the taking of the testimony of a child that it finds just and appropriate, considering the interests of the child, the rights of the defendant, and any other relevant factors.

Tex. Code Crim. Proc. Ann. art. 38.074, § 3(b), (c), (d). In Article 38.074,

“‘[s]upport person’ means any person whose presence would contribute to the

welfare and well-being of a child.” Id. art. 38.074, § 1(2).

When the State called Linda to testify, the defense objected under Texas Rule

of Evidence 601, challenging Linda’s competency to testify. Outside of the jury’s

4 presence and prior to the trial court’s hearing to determine Linda’s competency to

testify, the following exchange occurred:

[Defense counsel]: I don’t have an objection to [the victim assistance person] sitting here for this hearing. It’s when the jury comes back in, Your Honor.

THE COURT: Go ahead and make your objection, please.

[Defense counsel]: Yes, Your Honor. The State has requested that one of their investigators who’s a law enforcement officer sit next to [Linda] during her testimony in front of the jury. That investigator is dressed in a DA investigator coat that has a shield, has a badge hanging from his neck. He also has a gun on his hip. He is sitting in very good view of the jury. And I will be supplementing the record with photographs for the record. We strongly object to this. Number one, I don’t think there’s been any showing that her testimony will be unreliable without him there.

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