Jessica Latrese Chatman v. State

CourtCourt of Appeals of Texas
DecidedApril 14, 2011
Docket13-10-00191-CR
StatusPublished

This text of Jessica Latrese Chatman v. State (Jessica Latrese Chatman 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
Jessica Latrese Chatman v. State, (Tex. Ct. App. 2011).

Opinion

NUMBERS 13-10-00190-CR AND 13-10-00191-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG 

JESSICA LATRESE CHATMAN,                                                          Appellant,

v.

THE STATE OF TEXAS,                                                      Appellee.

On appeal from the County Court at Law No. 5

of Montgomery County, Texas.

MEMORANDUM OPINION

Before Chief Justice Valdez and Justices Rodriguez and Benavides 

Memorandum Opinion by Justice Rodriguez

                Appellant Jessica Latrese Chatman challenges her conviction by a jury for possession of marihuana (appellate cause number 13-10-00190) and criminal trespass (appellate cause number 13-10-00191), both class B misdemeanors.[1]  See Tex. Health & Safety Code Ann. § 481.121(a), (b)(1) (Vernon 2010); Tex. Penal Code Ann. § 30.05(a)(1), (d)(1) (Vernon Supp. 2010).  By three issues, Chatman argues that:  (1) the evidence was legally insufficient to support her criminal trespass conviction because there was a "bona fide dispute" as to right-of-access; (2) her trial counsel was ineffective for failing to request a jury instruction on mistake of fact as to criminal trespass; and (3) the trial court erred in refusing her request, under article 38.23 of the code of criminal procedure, for a jury charge in her marihuana possession case regarding evidence seized in an alleged illegal entry by the police.  See Tex. Code Crim. Proc. Ann. art. 38.23 (Vernon 2005).  We affirm the judgment of conviction for criminal trespass and affirm as modified the judgment of conviction of possession of marihuana.

I.  Background

            In mid-March 2009, Chatman was arrested at the Cricket Hollow Apartments in Montgomery County, Texas.  At the time of her arrest, Chatman was present in the apartment from which she had been evicted over three weeks earlier.  The arresting police officers found marihuana in the apartment and on Chatman's person.

Chatman was charged by complaint and information for possession of marihuana as follows:  "on or about March 12, 2009, in Montgomery County, Texas, [Chatman], did intentionally or knowingly possess a usable quantity of marihuana in the amount of two ounces or less . . . ."  Chatman was also charged by complaint and information for criminal trespass as follows:  "on or about March 12, 2009, in Montgomery County Texas, [Chatman], did intentionally and knowingly enter a habitation of another, namely, Stephanie Eason, without the effective consent of Stephanie Eason, the owner, and [Chatman] did then and there have notice entry was forbidden . . . ." 

Chatman pleaded not guilty to both charges, and her case was tried to a jury.  The jury returned guilty verdicts.  For the marihuana possession conviction, the trial court sentenced Chatman to 180 days' confinement in county jail, suspended for one year of community supervision, and assessed a $500 fine; for the criminal trespass conviction, the court sentenced Chatman to two days in county jail, with credit for time served, and assessed a $300 fine.  This appeal followed.       

II.  Sufficiency of the Evidence

            By her first issue, Chatman complains that the evidence was legally insufficient to support her criminal trespass conviction because a bona fide dispute existed regarding Chatman's right to access the property in question.

A.  Standard of Review and Applicable Law

            When conducting a legal sufficiency review, a court must ask whether "any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt"—not whether "it believes that the evidence at the trial established guilt beyond a reasonable doubt."  Jackson v. Virginia, 443 U.S. 307, 318-19 (1979); see Brooks v. State, 323 S.W.3d 893, 912 (Tex. Crim. App. 2010).  A legal sufficiency analysis requires the court to view all of the evidence in "a light most favorable to the verdict."  Jackson, 443 U.S. at 319; see Laster v. State, 275 S.W.3d 512, 517 (Tex. Crim. App. 2009).  The trier of fact is the sole judge of the facts, the credibility of the witnesses, and the weight given to testimony.  Tex. Code Crim. Proc. Ann. art. 38.04 (Vernon 1979); Beckham v. State, 29 S.W.3d 148, 151 (Tex. App.–Houston [14th Dist.] 2000, pet. ref'd).  We do not reevaluate the weight or credibility of the evidence, nor do we substitute our own conclusions for the trier of fact.  King v. State, 29 S.W.3d 556, 562 (Tex. Crim. App. 2000) (en banc).  Instead, we resolve any inconsistencies in the evidence in favor of the final judgment and consider whether the jury reached a rational decision.  Curry v. State, 30 S.W.3d 394, 406 (Tex. Crim. App. 2000).

            Legal sufficiency is measured by the elements of the offense as defined by a hypothetically correct jury charge.  Villarreal v. State, 286 S.W.3d 321, 327 (Tex. Crim. App. 2009); Malik v. State, 953 S.W.2d 234, 240 (Tex. Crim. App. 1997).  "Such a charge is one that accurately sets out the law, is authorized by the indictment, does not unnecessarily increase the State's burden of proof or unnecessarily restrict the State's theories of liability, and adequately describes the particular offense for which the defendant was tried."  Villarreal, 286 S.W.3d at 327; see Malik, 953 S.W.2d at 240.  The elements of class B misdemeanor criminal trespass are that:  (1) a person, (2) without effective consent, (3) enters or remains on the property of another, (4) knowingly or intentionally, (5) when she had notice that entry was forbidden.  See Day v. State, 532 S.W.2d 302, 306 (Tex. Crim. App. 1976) (op. on reh'g); see also Tex. Penal Code Ann.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Curry v. State
30 S.W.3d 394 (Court of Criminal Appeals of Texas, 2000)
Madden v. State
242 S.W.3d 504 (Court of Criminal Appeals of Texas, 2007)
Laster v. State
275 S.W.3d 512 (Court of Criminal Appeals of Texas, 2009)
Beckham v. State
29 S.W.3d 148 (Court of Appeals of Texas, 2000)
King v. State
29 S.W.3d 556 (Court of Criminal Appeals of Texas, 2000)
Hann v. State
771 S.W.2d 731 (Court of Appeals of Texas, 1989)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Stafford v. State
813 S.W.2d 503 (Court of Criminal Appeals of Texas, 1991)
Cooper v. State
45 S.W.3d 77 (Court of Criminal Appeals of Texas, 2001)
Saylor v. State
660 S.W.2d 822 (Court of Criminal Appeals of Texas, 1983)
Day v. State
532 S.W.2d 302 (Court of Criminal Appeals of Texas, 1976)
Villarreal v. State
286 S.W.3d 321 (Court of Criminal Appeals of Texas, 2009)
Roberts v. State
220 S.W.3d 521 (Court of Criminal Appeals of Texas, 2007)
Kemp v. State
892 S.W.2d 112 (Court of Appeals of Texas, 1995)
Moreno v. State
1 S.W.3d 846 (Court of Appeals of Texas, 1999)
Goodspeed v. State
187 S.W.3d 390 (Court of Criminal Appeals of Texas, 2005)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Jaynes v. State
216 S.W.3d 839 (Court of Appeals of Texas, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Jessica Latrese Chatman v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jessica-latrese-chatman-v-state-texapp-2011.