Jason A. Snavely v. State

CourtCourt of Appeals of Texas
DecidedMarch 10, 2016
Docket01-15-00185-CR
StatusPublished

This text of Jason A. Snavely v. State (Jason A. Snavely 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
Jason A. Snavely v. State, (Tex. Ct. App. 2016).

Opinion

Opinion issued March 10, 2016

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-15-00185-CR ——————————— JASON A. SNAVELY, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 230th District Court Harris County, Texas Trial Court Case No. 1404979

MEMORANDUM OPINION

A jury convicted appellant, Jason A. Snavely, of aggravated assault of a

family member,1 enhanced by a previous felony conviction for aggravated robbery,

1 See TEX. PENAL CODE ANN. § 22.02(a)(2) (West 2011). and assessed his punishment at fifty-five years’ confinement. In one point of error,

appellant contends that his trial counsel was ineffective for presenting an

inapplicable defense at the guilt-innocence phase of trial. We affirm.

Background

Odell “Joe” Jackson shared a home in Houston with his nephews,

Christopher Wetzel and appellant, appellant’s girlfriend, Susan Allen, and their

two-year old son. On October 15, 2013, Jackson and Wetzel were sitting in their

backyard and talking when they heard what sounded like a firecracker go off in the

house. The sound occurred because appellant had picked up a shotgun and fired a

shot through his bedroom door, where Allen and his son were located. Appellant

then opened the back door and shot Wetzel in the face, and turned to Jackson and

told him, “you’re next.” Jackson jumped behind appellant, grabbed the shotgun,

and held it against appellant’s chest while Wetzel ran across the street for help.

Once appellant was calm, Jackson released him and they walked inside the house.

When appellant grabbed a knife in the kitchen, Jackson ran outside and gave the

shotgun to firefighters who had arrived at the scene. Upon emerging from the

house, appellant was placed under arrest.

Before trial, appellant’s appointed counsel sought psychiatric evaluations of

appellant to determine both his competency to stand trial and his sanity at the time

of the charged offense. The evaluator found that appellant was competent to stand

2 trial and that his state of mind at the time of the conduct charged did not satisfy the

statutory criteria for insanity.

At trial, counsel cross-examined the State’s witnesses. Jackson testified that

he was aware that appellant has had mental issues and that, on the morning of the

shooting, he and Wetzel had discussed hallucinations that appellant had

experienced the previous night. Allen, a defense witness, testified that she met

appellant at a mental hospital twenty-eight years ago and that appellant suffered

from back pain and depression as a result of the pain. She further testified that

appellant appeared dazed and in a fog on the morning of the shooting. Appellant

testified that, on the night before the shooting, he was feeling a bit depressed and

asked Wetzel to give him something for his headache. He testified that after he

took the pill Wetzel gave him, he felt dizzy and strange and had difficulty falling

asleep. Appellant testified that he remembered waking up the morning of the

shooting and then being arrested outside his house, but that he did not recall

anything else. In his closing argument, trial counsel argued that the State had

failed to prove that appellant intentionally or knowingly caused Wetzel’s injuries.

The jury found appellant guilty of aggravated assault of a family member.

Having found the enhancement paragraph alleging a prior felony conviction for

aggravated robbery true, the jury assessed appellant’s punishment at fifty-five

years’ confinement. Appellant timely filed this appeal.

3 Discussion

In his sole point of error, appellant contends that his trial counsel was

ineffective because he misunderstood the law and presented an inapplicable

defense of involuntary intoxication at the guilt-innocence phase of trial.

A. Standard of Review

The standard of review for evaluating claims of ineffective assistance of

counsel is set forth in Strickland v. Washington. 466 U.S. 668, 687, 104 S. Ct.

2052, 2064 (1984). Under the Strickland two-step analysis, a defendant must

demonstrate that (1) his counsel’s performance fell below an objective standard of

reasonableness and (2) there is a reasonable probability that, but for counsel’s

unprofessional errors, the result of the proceeding would have been different. Id.

at 687–88, 694, 104 S. Ct. at 2064, 2068; Andrews v. State, 159 S.W.3d 98, 101–02

(Tex. Crim. App. 2005). A reasonable probability is a “probability sufficient to

undermine confidence in the outcome.” Strickland, 466 U.S. at 694, 104 S. Ct. at

2068. Failure to make the required showing of either deficient performance or

sufficient prejudice defeats the ineffectiveness claim. See Williams v. State, 301

S.W.3d 675, 687 (Tex. Crim. App. 2009); Andrews, 159 S.W.3d at 101.

An appellant bears the burden of proving by a preponderance of the

evidence that his counsel was ineffective. Thompson v. State, 9 S.W.3d 808, 813

(Tex. Crim. App. 1999). Any allegation of ineffectiveness must be firmly founded

4 in the record, and the record must affirmatively demonstrate the alleged

ineffectiveness. Id. at 814. When the record is silent, we may not speculate to find

trial counsel ineffective. Garcia v. State, 57 S.W.3d 436, 440 (Tex. Crim. App.

2001). In reviewing counsel’s performance, we look to the totality of the

representation to determine the effectiveness of counsel, indulging a strong

presumption that counsel’s performance is within a wide range of reasonable

professional assistance and trial strategy. See Robertson v. State, 187 S.W.3d 475,

482–83 (Tex. Crim. App. 2006); Thompson, 9 S.W.3d at 813. We will find a

counsel’s performance deficient only if the conduct is so outrageous that no

competent attorney would have engaged in it. Andrews, 159 S.W.3d at 101.

“When handed the task of determining the validity of a defendant’s claim of

ineffective assistance of counsel, any judicial review must be highly deferential to

trial counsel and avoid the deleterious effects of hindsight.” Thompson, 9 S.W.3d

at 813 (citing Ingham v. State, 679 S.W.2d 503, 509 (Tex. Crim. App. 1984)).

B. Analysis

Appellant contends that his trial counsel was ineffective because he

misunderstood the law and presented the inapplicable defense of involuntary

intoxication at the guilt-innocence stage of trial.

“A person commits an offense only if he voluntarily engages in conduct,

including an act, an omission, or possession.” TEX. PENAL CODE ANN. § 6.01(a)

5 (West 2011). “Involuntary intoxication” may constitute an affirmative defense to

the commission of a crime if it is shown that (1) the accused exercised no

independent judgment or volition in taking the intoxicant, and (2) as a result of a

“severe mental disease or defect” caused by the involuntary intoxicant, the accused

did not know that his conduct was wrong. Mendenhall v.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Williams v. State
301 S.W.3d 675 (Court of Criminal Appeals of Texas, 2009)
Mendenhall v. State
77 S.W.3d 815 (Court of Criminal Appeals of Texas, 2002)
Robertson v. State
187 S.W.3d 475 (Court of Criminal Appeals of Texas, 2006)
Andrews v. State
159 S.W.3d 98 (Court of Criminal Appeals of Texas, 2005)
Thompson v. State
9 S.W.3d 808 (Court of Criminal Appeals of Texas, 1999)
Garcia v. State
57 S.W.3d 436 (Court of Criminal Appeals of Texas, 2001)
Ingham v. State
679 S.W.2d 503 (Court of Criminal Appeals of Texas, 1984)
Lopez v. State
343 S.W.3d 137 (Court of Criminal Appeals of Texas, 2011)

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