Joe Don Strickland v. State

CourtCourt of Appeals of Texas
DecidedSeptember 11, 2007
Docket06-06-00238-CR
StatusPublished

This text of Joe Don Strickland v. State (Joe Don Strickland 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
Joe Don Strickland v. State, (Tex. Ct. App. 2007).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana



______________________________



No. 06-06-00238-CR



JOE DON STRICKLAND, Appellant



V.



THE STATE OF TEXAS, Appellee





On Appeal from the 124th Judicial District Court

Gregg County, Texas

Trial Court No. 33341-B





Before Morriss, C.J., Carter and Moseley, JJ.

Memorandum Opinion by Justice Moseley



MEMORANDUM OPINION



Joe Don Strickland drove his vehicle across a centerline and crashed into a car driven by Daniel Blalock, who was severely injured in the collision. Blalock's injuries included damage to his body such that his liver was extruding from his body when he was taken to the hospital. A jury convicted Strickland of intoxication assault and assessed his punishment at ten years' imprisonment, a result from which Strickland appeals.

Strickland raises two issues on appeal. He first contends that the trial court erred by admitting overly prejudicial photographs which showed, in graphic detail, the physical injuries sustained by Blalock. As a second point, Strickland contends that the results of a blood test taken shortly after the collision should not have been admitted into evidence because he had not willingly consented to the seizure of his blood.

Photographs of the Victim's Injuries

Strickland's first contention boils down to the argument that it was unfairly prejudicial or inflammatory for the jury to have been permitted to see the photographs taken of Blalock and the injuries he sustained; these were used by the physician as a prop to explain the nature of the injuries and the treatment used by medical personnel in caring for Blalock. The photographs depict the injuries incurred during the accident and show the process of treatment immediately after Blalock arrived at the trauma center. In analyzing whether such photographs are unfairly prejudicial or inflammatory, however, the caselaw generally makes reference to an "undue tendency" to suggest decision on an "improper basis" such as an "emotional one." Saldano v. State, No. AP-72556, 2007 WL 1610422, at *19 (Tex. Crim. App. June 6, 2007); see Newbury v. State, 135 S.W.3d 22, 43 (Tex. Crim. App. 2004). The photographs in this case depict the result of Strickland's actions and what the verbal testimony properly described. See Newbury, 135 S.W.3d at 43.

The admissibility of a photograph is within the sound discretion of the trial court. Shuffield v. State, 189 S.W.3d 782, 786 (Tex. Crim. App. 2006). That decision to admit or exclude evidence will not be overturned on appeal absent a showing that the trial court abused its discretion. Id. at 787. The Texas Rules of Evidence favor the admission of all relevant evidence at trial, though these evidentiary rules do provide exceptions that would exclude otherwise relevant and admissible evidence. See Tex. R. Evid. 401. One of those exceptions to the admissibility of evidence appears in Rule 403 of the Texas Rules of Evidence: "Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, or needless presentation of cumulative evidence." Tex. R. Evid. 403.

In the event that an appellant challenges the propriety of the trial court's admission of evidence over a Rule 403 objection, an appellate court should consider a number of factors, including:



(1) how probative the evidence is;

(2) the potential of the evidence to impress the jury in some irrational, but nevertheless indelible way;



(3) the time the proponent needs to develop the evidence; and



(4) the proponent's need for the evidence.



Shuffield, 189 S.W.3d at 787. The reviewing court should also take into account other factors as well, including:

the number of photographs, the size of the photograph, whether it is in color or black and white, the detail shown in the photograph, whether the photograph is gruesome, whether the body is naked or clothed, and whether the body has been altered since the crime in some way that might enhance the gruesomeness of the photograph to the appellant's detriment.

Ledbetter v. State, 208 S.W.3d 723, 731-33 (Tex. App.--Texarkana 2006, no pet.).

In his testimony in this case, Blalock's treating physician used the photographs to explain the nature of the injuries and to explain the procedures used to treat Blalock. He carefully explained the types of injuries to Blalock resulting from the automobile collision caused by Strickland and the purposes of the various tubes inserted into Blalock's abdomen and what was necessary for him to recover from those injuries. The photographs were obviously probative. The photographs were undoubtedly explicit (as they would necessarily be for use with such explanations), but they were not more emotionally loaded than any usual clinical photograph of a patient who had sustained serious wounds. There was nothing about the photographs that would raise any undue tendency to suggest that a decision would be made by the jury on an emotional, rather than a rational, basis as a result of viewing them. The time needed to develop the evidence was insignificant; although (as in almost any case) verbal descriptions could have been utilized in lieu of the photographs, use of the photographs eliminated much of the guesswork in which the jury would otherwise have been required to indulge in order to understand the nature and severity of the injuries. (1)

Under these circumstances, the trial court would not have abused its discretion to determine that any tendency of the photographs to suggest the making of a decision by the jury on an emotional basis was not "undue" or that any "undue tendency" to suggest a decision on an emotional basis did not "substantially outweigh" or even "outweigh" the probative value of the photographs. See id.; see also Escamilla v. State, 143 S.W.3d 814, 826 (Tex. Crim. App. 2004) (trial court did not abuse its discretion to admit autopsy photographs because they helped explain the medical testimony describing the victim's various injuries caused by the defendant). The contention of error is overruled.

Blood Test Results

Strickland next contends that the trial court erred by admitting into evidence the results of his blood test.

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Related

Bumper v. North Carolina
391 U.S. 543 (Supreme Court, 1968)
Escamilla v. State
143 S.W.3d 814 (Court of Criminal Appeals of Texas, 2004)
Shuffield v. State
189 S.W.3d 782 (Court of Criminal Appeals of Texas, 2006)
Newbury v. State
135 S.W.3d 22 (Court of Criminal Appeals of Texas, 2004)
Aliff v. State
627 S.W.2d 166 (Court of Criminal Appeals of Texas, 1982)
Saldano v. State
232 S.W.3d 77 (Court of Criminal Appeals of Texas, 2007)
Cisneros v. State
165 S.W.3d 853 (Court of Appeals of Texas, 2005)
Erdman v. State
861 S.W.2d 890 (Court of Criminal Appeals of Texas, 1993)
Ledbetter v. State
208 S.W.3d 723 (Court of Appeals of Texas, 2006)
Harrison v. State
205 S.W.3d 549 (Court of Criminal Appeals of Texas, 2006)
Texas Department of Public Safety v. Latimer
939 S.W.2d 240 (Court of Appeals of Texas, 1997)

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Joe Don Strickland v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joe-don-strickland-v-state-texapp-2007.