Jamie Ray Watkins v. State

CourtCourt of Appeals of Texas
DecidedApril 9, 2020
Docket05-19-00557-CR
StatusPublished

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Bluebook
Jamie Ray Watkins v. State, (Tex. Ct. App. 2020).

Opinion

AFFIRM; Opinion Filed April 9, 2020

In The Court of Appeals Fifth District of Texas at Dallas No. 05-19-00557-CR

JAMIE RAY WATKINS, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 282nd Judicial District Court Dallas County, Texas Trial Court Cause No. F18-14134-S

MEMORANDUM OPINION Before Justices Schenck, Osborne, and Reichek Opinion by Justice Schenck Jamie Ray Watkins appeals from a conviction for burglary of a habitation with

the intent to commit a felony. We affirm the trial court’s judgment. Because all

issues are settled in the law, we issue this memorandum opinion. TEX. R. APP. P.

47.4.

BACKGROUND

Beginning in 2016, appellant lived with T.H., their child I.W., and T.H.’s

other minor daughter T.C. On or about July 20, 2018, appellant and T.H. got into a

heated argument, after which T.H. told appellant to leave the house. Appellant packed some clothes and walked out of the house. T.H. followed appellant out of

the house to ask for the house key, but appellant refused to give it to her. That

evening, T.H.’s father changed the lock on the front door. The next day, appellant

sent T.H. a series of text messages that began with apologies and ended with

statements she perceived as threatening.

In the evening of July 22, T.H. heard a noise outside her bedroom window

and looked out to see appellant’s car parked in the driveway. T.H. called 9-1-1 and

shouted to I.W. and T.C. to call their grandfather and other people for help. T.H.

then saw appellant break in through the backdoor and charge towards her, so she and

T.C. ran into I.W.’s bedroom where I.W. was awake watching videos on her

phone. I.W. jumped off her bed and turned on the light. Appellant entered I.W.’s

bedroom and punched T.H. several times before quickly leaving the house. T.H.

called 9-1-1 again, and the police and T.H.’s father arrived at the house where they

saw visible red marks on T.H.’s face.

Appellant was indicted for burglary of a habitation with the intent to commit

a felony. The indictment also alleged appellant had a dating relationship T.H. and

was a member of her household and that appellant had a prior conviction for a family

violence offense. Appellant pleaded not guilty, and the case proceeded to trial

before a jury. The jury found appellant guilty as charged in the indictment and

sentenced him to twenty-two years’ confinement. Appellant timely filed this

appeal. –2– DISCUSSION

I. Denial of Mistrial

In his first issue, appellant argues the trial court erred in denying his request

for a mistrial after T.H.’s father testified appellant had been incarcerated.

The complained-of statement took place during the prosecutor’s examination

of T.H.’s father:

Q: …well, when did you come to learn about [T.H.’s] relationship with [appellant]?

A: Actually, um, I think on the day that – um, that we actually knew of him was, uh, pretty much when my daughter told me that, um, she was pregnant and – um, but we didn’t get to know of him really because it was kind of secretive, if you want to say.

Q: Okay.

A: But, um, didn’t know him until – um, possibly of him really is, uh, when he got incarcerated.

At that point, defense counsel objected, and the trial judge dismissed the jury from

the courtroom. Outside the presence of the jury, the prosecutor questioned T.H.’s

father and established he had been instructed not to refer to appellant’s prior

incarceration. Defense counsel requested a mistrial based on “previous rulings of

the Court concerning prior convictions and extraneous offenses.” The trial court

denied that request for mistrial and instead brought the jury back into the courtroom

and issued an instruction to disregard T.H.’s father’s last statement.

Our standard of review of a trial court’s ruling on a motion for mistrial is

abuse of discretion. Webb v. State, 232 S.W.3d 109, 112 (Tex. Crim. App. 2007).

–3– We view the evidence in the light most favorable to the trial court’s ruling and

uphold the trial court’s ruling if it was within the zone of reasonable

disagreement. Id. We may not substitute our judgment for that of the trial court, but

rather we decide whether the trial court’s decision was arbitrary or

unreasonable. See id. Thus, a trial court abuses its discretion in denying a motion

for new trial only when no reasonable view of the record could support the trial

court’s ruling. See id.

A mistrial is appropriate in “extreme circumstances” for a narrow class of

highly prejudicial and incurable errors. See Ocon v. State, 284 S.W.3d 880, 884

(Tex. Crim. App. 2009). Whether an error requires a mistrial must be determined

by the particular facts of the case. Id. Because it is an extreme remedy, a mistrial

should be granted “only when residual prejudice [would] remain[ ]” after less drastic

alternatives are explored. Id. Less drastic alternatives include instructing the jury

“to consider as evidence only the testimony and exhibits admitted through witnesses

on the stand,” and, questioning the jury “about the extent of any prejudice,” if

instructions alone do not sufficiently cure the problem. Id. Though requesting

lesser remedies is not a prerequisite to a motion for mistrial, when the movant does

not first request a lesser remedy, we will not reverse the court’s judgment if any

improper harm could have been cured by the less drastic alternative. Id.

Given the fact that the trial court gave a limiting instruction to the jury, it

appears from this record that the trial court agreed with appellant that T.H.’s father’s –4– statement was not admissible. See TEX. R. EVID. 404(b) (prohibiting admission of

evidence of prior crime, wrong, or other act to show that on a particular occasion the

person acted in accordance with the character). However, testimony referring to or

implying extraneous offenses allegedly committed by the appellant may be rendered

harmless by an instruction from the trial court unless it appears the evidence was so

clearly calculated to inflame the minds of the jury or is of such damning character

as to suggest it would be impossible to remove the harmful impression from the

jury’s mind. See Kemp v. State, 846 S.W.2d 289, 308 (Tex. Crim. App. 1992).

Appellant argues the complained-of statement was so prejudicial that a

limiting instruction could not cure the harmful effect. As support, he relies on the

fact that during their deliberations in the guilt-innocence phase of trial, the jurors

sent a note that read, “Do we decide the sentence length? Do we need to decide that

now? What are the procedures after the verdict? We are concerned about

safety.” Appellant urges that T.H.’s statement regarding prior incarceration must

have had the speaker’s desired effect of persuading jury that appellant was a bad

person or criminal in general.

Review of the record establishes the jury heard evidence that appellant had

threatened T.H., broken into her home, and physically assaulted her in front of her

children. The jury also heard evidence that appellant had a prior conviction for

assault domestic violence. Moreover, the complained-of statement was elicited after

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Related

Green v. United States
365 U.S. 301 (Supreme Court, 1961)
Rayford v. State
125 S.W.3d 521 (Court of Criminal Appeals of Texas, 2003)
Kemp v. State
846 S.W.2d 289 (Court of Criminal Appeals of Texas, 1992)
Webb v. State
232 S.W.3d 109 (Court of Criminal Appeals of Texas, 2007)
Ocon v. State
284 S.W.3d 880 (Court of Criminal Appeals of Texas, 2009)
McClintick v. State
508 S.W.2d 616 (Court of Criminal Appeals of Texas, 1974)
Tenon v. State
563 S.W.2d 622 (Court of Criminal Appeals of Texas, 1978)
Devoe, Paul Gilbert
354 S.W.3d 457 (Court of Criminal Appeals of Texas, 2011)

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Jamie Ray Watkins v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jamie-ray-watkins-v-state-texapp-2020.