Jason Christopher Miears v. State

CourtCourt of Appeals of Texas
DecidedMay 15, 2013
Docket04-11-00531-CR
StatusPublished

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Bluebook
Jason Christopher Miears v. State, (Tex. Ct. App. 2013).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION Nos. 04-11-00531-CR, 04-11-00532-CR & 04-11-0533-CR

Jason Christopher MIEARS, Appellant

v.

The STATE of Texas, Appellee

From the 379th Judicial District Court, Bexar County, Texas Trial Court Nos. 2009-CR-6566, 2009-CR-6567 & 2009-CR-6568 Honorable Ron Rangel, 1 Judge Presiding

Opinion by: Luz Elena D. Chapa, Justice

Sitting: Karen Angelini, Justice Patricia O. Alvarez, Justice Luz Elena D. Chapa, Justice

Delivered and Filed: May 15, 2013

AFFIRMED

Jason Miears pleaded guilty to charges of murder and aggravated robbery, and the trial

court sentenced him to fifty years in prison and to pay a fine of $2,500. Miears appeals the

judgments based on matters heard and ruled on before his plea. His first two issues concern

alleged errors at his competency trial: first, the trial court failed to exclude unreliable expert

testimony, and second, the jury’s verdict was contrary to the evidence. In his final issue, Miears

1 This case was assigned to the 379th Judicial District Court of Bexar County, Texas, in which the Honorable Ron Rangel is the presiding judge. Judge Rangel ruled on Miears’s motion to suppress and presided over the plea hearing. However, the competency trial was conducted by the Honorable Andrew W. Carruthers, Criminal Magistrate Judge. 04-11-00531-CR, 04-11-00532-CR & 04-11-00533-CR

complains the trial court wrongly denied his motion to suppress evidence found in his car. We

affirm.

THE COMPETENCY TRIAL

Miears contends that the testimony of the State’s expert witness was unreliable and

therefore inadmissible, and that the jury’s verdict was against the great weight and

preponderance of the evidence.

As a defendant, Miears is presumed competent to stand trial, and he had the burden of

proving otherwise by the preponderance of the evidence. TEX. CODE CRIM. PROC. ANN. art.

46B.003(b) (West 2006). Incompetency is shown if a defendant lacks (1) the sufficient present

ability to consult with the defendant’s attorneys with a reasonable degree of rational

understanding; or (2) a rational as well as factual understanding of the proceedings against the

defendant. Id. art. 46B.003(a) (West 2006).

The Evidence

The defense’s expert, Dr. Randall Sellers, interviewed Miears three times and assessed

his competency with a clinical interview and two structured or semi-structured interviews. Dr.

Sellers also spoke with Miears’s mother, a psychiatrist, to determine whether some of Miears’s

abnormal behaviors had existed since childhood. Dr. Sellers testified Miears was very intelligent

and knowledgeable about criminal law and the charges pending against him. He also testified

Miears suffered from or had elements of four mental illnesses: obsessive compulsive disorder, a

mood disorder, pervasive development disorder, and obsessive compulsive personality disorder.

In Dr. Sellers’s opinion, Miears’s illnesses would keep him from rationally coordinating

his defense with his lawyer despite his intelligence. He testified that Miears, because of his

intelligence, would fixate on a particular legal strategy or theory; it would then be impossible for

anyone to convince him that it was incorrect or that another one was better. -2- 04-11-00531-CR, 04-11-00532-CR & 04-11-00533-CR

Dr. Sellers also administered two tests to see if Miears was malingering—exaggerating

symptoms or behaviors to achieve some secondary gain. He found signs of malingering in one

test, but not in the other.

On cross-examination, Dr. Sellers clarified he thought Miears was incompetent to be tried

only because Miears lacked the sufficient present ability to consult with his attorneys with a

reasonable degree of rational understanding. He explained that, although sometimes defendants

make bad choices and do not properly consult with their attorneys, in his opinion the mental

illnesses he saw in Miears would impair him from rationally consulting with his attorneys. He

further testified Miears’s lack of cooperation with the State’s expert could stem from defensive

rigidity arising from his mental illnesses, or that it could be an example of Miears trying to

manipulate the State’s expert witness, Dr. Brian Skop.

Dr. Skop did not offer an ultimate opinion about Miears’s competency, but he did testify

Miears was malingering and displayed elements of competency. Dr. Skop attempted five

interviews with Miears; three of the interviews were unsuccessful because Miears absolutely

refused to cooperate. During the first of the two interviews Miears participated in, he appeared

to be psychotic, had delusions or hallucinations, and became so threatening and agitated—

including using profanity and offering to perform sex acts on Dr. Skop—that Dr. Skop ended the

interview after forty-five minutes. He began to suspect Miears was malingering because he

knew Miears was in a mental unit meant for relatively functional inmates, and the behavior he

had observed in the interview strongly conflicted with that designation. During the second

interview, which lasted seventy-five minutes, Dr. Skop administered a test for malingering, the

results of which were “positive off the charts.” Because he suspected Miears was malingering,

Dr. Skop began to investigate other evidence.

-3- 04-11-00531-CR, 04-11-00532-CR & 04-11-00533-CR

Dr. Skop reviewed the reports of Dr. Maria Ruiz-Sweeney, who was one of Miears’s

doctors while in jail. She initially diagnosed him as incompetent in her May 2009 report.

However, after a period of time he was on medication, Dr. Ruiz-Sweeney ultimately concluded

in her October 2009 report, Miears was malingering and he was competent to stand trial. Dr.

Skop found her assessment matched his own independent diagnosis. Dr. Skop listened to

recorded phone calls between Miears and his father, who is a criminal defense attorney. Miears

asked his father to research certain cases for him and bragged he had “pulled one over” on Dr.

Sweeny. Dr. Skop also reviewed the initial police interview and found evidence that showed

Miears was interacting very rationally and coherently with the officer. Dr. Skop thought

Miears’s behavior in that interview and on the phone displayed a rational and coherent

understanding of how to interact in a cooperative way. Dr. Skop also examined Miears’s

academic history, spoke with detention officers supervising Miears, reviewed police reports, and

looked at motions Miears had filed. The motions were often filled with nonsense—“saying that

his attorney is not an attorney, that everybody has AIDS”—which, when contrasted with his

cooperative and functional behavior with other people, formed part of the basis for Dr. Skop’s

diagnosis of malingering.

The State called the custodian of records for the University of Texas at San Antonio to

introduce Miears’s academic transcript into evidence. The transcript shows Miears earned his

Bachelor of Arts degree in political science cum laude, graduated with a final GPA of 3.52, and

received the distinction of being variously placed on the Honor Roll, Dean’s List, and President’s

List in several semesters. At the time of his arrest, he was a graduate student at UTSA.

The first lay witness was David Martinez, a detention officer with the Bexar County

Sheriff’s Office. Martinez regularly oversaw Miears for a period of five or six months, but had

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