Jamie Lou Tyler v. State

CourtCourt of Appeals of Texas
DecidedApril 15, 2004
Docket01-02-01146-CR
StatusPublished

This text of Jamie Lou Tyler v. State (Jamie Lou Tyler 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.

Bluebook
Jamie Lou Tyler v. State, (Tex. Ct. App. 2004).

Opinion

Opinion issued April 15, 2004





In The

Court of Appeals

For The

First District of Texas





NO. 01-02-01146-CR





JAMIE LOU TYLER, Appellant


V.


THE STATE OF TEXAS, Appellee





On Appeal from the 10th District Court

Galveston County, Texas

Trial Court Cause No. 02CR0503





O P I N I O N


          After a bench trial, the trial court convicted appellant Jamie Lou Tyler of felony misapplication of fiduciary property and assessed punishment at confinement for one year, probated for three years. The trial court further ordered that Tyler pay restitution in the amount of $16,177. Tyler contends on appeal that the trial court erred in (1) denying her motion for instructed verdict; (2) violating the ex-post-facto provisions of the United States and Texas constitutions; and (3) ordering restitution to be paid to persons other than the victim alleged in the indictment. We reform the judgment and affirm.

Facts

          Howard and Grace Rogers had five children and many grandchildren. Howard died in February 1995, leaving his estate to Grace. Their son, Michael, helped organize Howard’s estate and at that time, Grace held about $48,000 in cash assets. Appellant Tyler married one of the Rogers’ grandchildren, Stephen Kadlecek. Grace developed a close relationship with Tyler after the birth of Tyler’s daughter, Grace’s great-granddaughter. In 1995, Tyler volunteered to assist Grace with her financial affairs.

          Grace added Tyler as a signatory on her bank accounts, and executed a durable power of attorney naming Tyler as her “agent (attorney-in-fact).” The power of attorney gave Tyler power over all of Grace’s assets. Between February 1995 and June 1997, Tyler withdrew approximately $48,000 from Grace’s bank account. Tyler spent some of Grace’s money on improvements to Tyler’s home, and on loan payments for Tyler’s automobiles and mortgage. In August 1997, Grace revoked the power of attorney, and Michael began again to manage her financial affairs. At that point, Grace’s bank account contained less than $150. Grace died before the inception of these criminal proceedings.

Legal Sufficiency

          Tyler contends that the trial court erred in denying her motion for directed verdict. A challenge on appeal to the denial of a motion for directed verdict is a challenge to the legal sufficiency of the evidence. Williams v. State, 937 S.W.2d 479, 482 (Tex. Crim. App. 1996). When evaluating the legal sufficiency of the evidence, we should view the evidence in the light most favorable to the verdict and determine whether any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt. Swearingen v. State, 101 S.W.3d 89, 95 (Tex. Crim. App. 2003).

          Section 32.45 of the Texas Penal Code defines the offense of misapplication of fiduciary property, providing in pertinent part:

A person commits an offense if he intentionally, knowingly, or recklessly misapplies property he holds as a fiduciary or property of a financial institution in a manner that involves substantial risk of loss to the owner of the property or to a person for whose benefit the property is held.


Tex. Pen. Code Ann. § 32.45 (Vernon Supp. 2004). Tyler contends the evidence is legally insufficient because the trial court remarked during a hearing on Tyler’s motion for directed verdict that Tyler had no formal trustee relationship with Grace, and therefore a fiduciary relationship “may not have” existed. As the law requires the trial court to find that a fiduciary relationship exists in order to find guilt, Tyler contends that the trial court’s observation negates any criminal liability on her part.

          Tyler’s contention ignores the fact that after closing argument, the trial court found beyond a reasonable doubt that Tyler misappropriated funds belonging to Grace Rogers and that she committed a criminal offense by “knowingly or recklessly misapplying property she held in a fiduciary capacity.” The trial court further clarified its finding when it explained that “. . . those funds were given to her by virtue of that power of attorney, [and] when she deposited them into the Amoco Credit Union and then withdrew them into her own account . . . she was acting in a fiduciary capacity and misapplied funds.”

          The record contains legally sufficient evidence to support the trial court’s findings that Tyler acted as a fiduciary and misapplied funds. The power of attorney that Grace executed in April 1995, admitted into evidence, named Tyler as her “agent (attorney-in-fact).” While Tyler served in that capacity, in April 1995, she transferred $4,123.46 from Grace’s account to her own personal bank account, and kept $1,000 in cash. In January 1996, she withdrew another $2,663.65 from the bank account, and used the funds to install cabinets in her home on Tiki Island. In February 1996, Tyler transferred $5,400 from Grace’s bank account to her own personal bank account. In June and July 1996, Tyler drew checks on Grace’s bank account, each in the amount of $942.30, to make monthly payments on auto loans. In July and August 1996, Tyler drew checks on the account, each in the amount of $1,091.10, payable to “Countrywide” for mortgage payments on Tyler’s home.

          Michael Rogers testified at trial that after Grace revoked Tyler’s power of attorney, he assumed responsibility for managing her financial affairs. He testified that during the time period between February 1995 and June 1997, $48,000 had been removed from Grace’s bank account, and that Grace did not have any financial obligations or needs that necessitated $48,000 in withdrawals. While Michael Rogers managed her financial affairs, Grace’s living expenses rarely exceeded her monthly income of approximately $1,500. Michael testified that after Grace revoked Tyler’s power of attorney, the relationship between Tyler and Grace drastically changed, and that Tyler may have visited Grace once before she died.

          Tyler further contends that the evidence is legally insufficient because Grace died before trial, and thus could not testify as to her relationship with Tyler and as to whether some of the funds Tyler withdrew were gifts. The trial court noted that based on the evidence of Mrs.

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Jamie Lou Tyler v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jamie-lou-tyler-v-state-texapp-2004.