Jason Dubois Sanders v. State

CourtCourt of Appeals of Texas
DecidedJuly 22, 2008
Docket14-06-01130-CR
StatusPublished

This text of Jason Dubois Sanders v. State (Jason Dubois Sanders 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 Dubois Sanders v. State, (Tex. Ct. App. 2008).

Opinion

Affirmed and Memorandum Opinion filed July 22, 2008

Affirmed and Memorandum Opinion filed July 22, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-06-01130-CR

JASON DUBOIS SANDERS, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 230th District Court

Harris County, Texas

Trial Court Cause No. 1049456

M E M O R A N D U M  O P I N I O N

Jason Dubois Sanders challenges the finding that he was competent to stand trial, asserting that the jury=s finding of competency was against the great weight and preponderance of the evidence.  We affirm.


Sanders was charged with the felony offense of capital murder.  He entered a plea of not guilty.  Sanders moved for a pretrial competency hearing and the trial court convened a jury for that purpose.  The defense presented the testimony of one expert witness in support of its contention that Sanders was incompetent to stand trial.  The State responded with the testimony of its own expert witness, as well as a former detention officer, a deputy sheriff, a criminal-defense lawyer who previously represented Sanders, Sanders=s former high-school principal, and Sanders=s co-defendant.  The jury found that the defense did not prove by a preponderance of the evidence that Sanders was incompetent to stand trial. 

The case proceeded to trial and the jury found Sanders guilty as charged.  The jury also answered three special issues: it answered the issue of mental retardation in the negative, the issue of future dangerousness in the affirmative, and the issue of mitigation in the affirmative.  The trial court assessed punishment at confinement for life in the Institutional Division of the Texas Department of Criminal Justice, without the possibility of parole.  This appeal timely followed. 

In his first four of eight issues, Sanders challenges the qualifications of the State=s expert witness, Dr. Denkowski.[1]  But Sanders refers to no place in the record where he timely objected to Dr. Denkowski=s qualifications.  On that point, therefore, Sanders has failed to preserve any error.  See Croft v. State, 148 S.W.3d 533, 544 (Tex. App.CHouston[14th Dist.] 2004, no pet.) (citing Tex. R. App. P. 33.1(a)).  Even if Sanders had preserved error, we find no support for his argument that an expert who testifies at a defendant=s competency trial must be appointed under article 46B.021 of the Code of Criminal Procedure, and must therefore satisfy the qualifications and requirements listed in articles 46B.022, 46B.024, and 46B.025.  See Code Crim. Proc. Ann. art. 46B.021, 46B.022, 46B.024 (Vernon 2004); see also Code Crim. Proc. Ann. art. 46B.025 (Vernon 2005).


In the final four issues, Sanders essentially challenges the factual sufficiency of the evidence.[2]  A person is incompetent to stand trial if the person does not have A(1) sufficient present ability to consult with the person=s lawyer with a reasonable degree of rational understanding; or (2) a rational as well as factual understanding of the proceedings against the person.@  Code Crim. Proc. Ann. art 46B.003(a) (Vernon 2004).  An accused is presumed to be competent to stand trial until he proves his incompetency by a preponderance of the evidence.  Williams v. State, 964 S.W.2d 747, 750 (Tex. App.CHouston[14th Dist.] 1998, pet. ref=d).  When evaluating the sufficiency of the evidence offered to support the denial of Sanders's affirmative defense, or any fact issue where the law has shifted to the defendant the burden of proof by a preponderance of the evidence, the correct standard of review is whether after considering all of the evidence relevant to the issue, "the judgment is so against the great weight and preponderance of the evidence so as to be manifestly unjust." Gallo v. State, 239 S.W.3d 757, 770 (Tex. Crim. App. 2007) (quoting Meraz v. State, 785 S.W.2d 146, 155 (Tex. Crim. App. 1990)).


The jury heard evidence on both sides of the issue.  The defense called Dr. Brown as its expert witness.  Before reaching his opinion, Dr. Brown reviewed various documents including medical records, Mental Health Mental Retardation Authority (MHMRA) records, and school records the State had provided.  Dr. Brown also met with Sanders, his mother, and his maternal grandmother, who had raised him.  Dr. Brown testified that Sanders was Aextremely slow intellectually@ and that Sanders had trouble giving useful information.  He performed a full intellectual evaluation of Sanders, using the Weschler Adult Intelligence Scale-III (WAIS-III) to measure intellectual capacity, or IQ.  Sanders scored a verbal IQ of 61, a performance IQ of 52, and a full-scale IQ of 52.  Dr. Brown testified that the average IQ is between 90 and 110, the standard deviation is 15 points, and approximately 70 percent of the population falls within one standard deviation above or below the mean.  Dr. Brown opined that Sanders was mildly to moderately retarded, which is considered high-functioning retardation, and that his impairment was permanent.  He told the jury that Sanders= understanding of his case was Avery, very simple and very, very primitive.@ 

In Dr. Brown=

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Related

Ex Parte Modden
147 S.W.3d 293 (Court of Criminal Appeals of Texas, 2004)
Williams v. State
191 S.W.3d 242 (Court of Appeals of Texas, 2006)
Wesbrook v. State
29 S.W.3d 103 (Court of Criminal Appeals of Texas, 2000)
Fuentes v. State
991 S.W.2d 267 (Court of Criminal Appeals of Texas, 1999)
Meraz v. State
785 S.W.2d 146 (Court of Criminal Appeals of Texas, 1990)
Croft v. State
148 S.W.3d 533 (Court of Appeals of Texas, 2004)
Gallo v. State
239 S.W.3d 757 (Court of Criminal Appeals of Texas, 2007)
Williams v. State
964 S.W.2d 747 (Court of Appeals of Texas, 1998)

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Jason Dubois Sanders v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jason-dubois-sanders-v-state-texapp-2008.