Jonathan Paul Jones v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 19, 2024
Docket13-23-00196-CR
StatusPublished

This text of Jonathan Paul Jones v. the State of Texas (Jonathan Paul Jones v. the State of Texas) 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
Jonathan Paul Jones v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

NUMBER 13-23-00196-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

JONATHAN PAUL JONES, Appellant,

v.

THE STATE OF TEXAS, Appellee.

ON APPEAL FROM THE 144TH DISTRICT COURT OF BEXAR COUNTY, TEXAS

OPINION

Before Chief Justice Contreras and Justices Benavides and Silva Opinion by Justice Benavides

On January 31, 2020, at around 1:00 a.m., appellant Jonathan Paul Jones entered

an exit ramp driving the wrong direction. As he reached the top of the ramp, Jones was

involved in a head-on collision with Taylor McCowan as she exited Loop 1604 in San

Antonio, Texas. McCowan later died from her injuries, and Jones was charged with intoxication manslaughter (Count I) and manslaughter (Count II), both second-degree

felonies. See TEX. PENAL CODE ANN. §§ 19.04, 49.08. The State’s primary theory of

causation at trial involved Jones’s alleged consumption of alcohol prior to the accident:

either he was legally intoxicated under Count I, or he was under the influence and his

decision to drive in that condition was reckless under Count II. The jury acquitted Jones

of intoxication manslaughter but found him guilty of manslaughter. The jury also found

that Jones used his vehicle as a deadly weapon and sentenced him to a term of

imprisonment for eleven years and six months.

Jones raises four issues on appeal: (1) his conviction on Count II after being

acquitted on Count I constituted a double-jeopardy violation; (2) the evidence was

insufficient to support his conviction under Count II because the jury implicitly rejected the

State’s intoxication evidence under Count I and the remaining evidence did not show

recklessness; (3) the trial court erred by excluding certain evidence as hearsay when it

was admissible under the optional completeness rule; and (4) the trial court erred by

excluding expert testimony about the route Jones may have taken before turning the

wrong way onto the exit ramp.1 We affirm.

I. BACKGROUND

Count I of the indictment alleged that Jones caused McCowan’s death by operating

a motor vehicle in a public place while intoxicated. Count II of the indictment alleged that

1 This appeal was transferred to us from the Fourth Court of Appeals in San Antonio pursuant to a

docket-equalization order issued by the Supreme Court of Texas. See TEX. GOV’T CODE ANN. §§ 22.220(a) (delineating the jurisdiction of appellate courts), 73.001 (granting the supreme court the authority to transfer cases from one court of appeals to another at any time that there is “good cause” for the transfer). We are bound by the precedent of the transferring court to the extent that it conflicts with our own. See TEX. R. APP. P. 41.3.

2 Jones recklessly caused McCowan’s death “by driving and operating a motor vehicle in

the opposite direction of traffic on a highway/roadway; and/or driving and operating a

motor vehicle while under the influence of alcohol.” Finally, the indictment included an

allegation that Jones used his vehicle as a deadly weapon.

As Jones acknowledges in his brief, “there was clearly sufficient evidence that

[Jones] caused the accident that killed [McCowan].” Instead, the primary dispute at trial

was what caused Jones to drive the wrong way up the exit ramp. Jones admitted to an

investigating officer at the scene that he had “two beers” earlier in the evening. The officer

testified that he observed several clues that indicated that Jones was intoxicated,

including the odor of alcohol on Jones’s breath, “unsteadiness,” “a noticeable sway,” and

slow responses to the officer’s questions. According to the same officer, Jones failed each

of the three standard field sobriety tests by exhibiting six out of six clues on the horizontal

gaze nystagmus test, five out of eight clues on the walk-and-turn test, and four clues on

the one-leg-stand test. The officer concluded that Jones was intoxicated and arrested

him. The State also introduced evidence that an involuntary blood draw taken at

approximately 3:00 a.m. showed that Jones’s blood alcohol concentration (BAC) at the

time of the draw was 0.177.

The State also suggested that Jones’s intoxication could be inferred from other

facts. The State introduced evidence that the exit ramp contained a “DO NOT ENTER”

sign visible to someone driving up the ramp and that other traffic control devices should

have alerted Jones to the fact that he could not turn that direction onto the exit ramp. For

example, Jones’s theory at trial was that he traveled up Barshop Blvd. to the frontage

3 road, crossed the frontage road, and turned left onto the exit ramp.2 The State pointed

out that, to travel this route, Jones necessarily crossed three lanes of one-way traffic at a

forty-five-degree angle, drove through a shoulder with solid white lines on either side, and

disregarded a raised concrete divider to his left. There were numerous maps and images

of the area admitted into evidence. The following image shows Jones’s alleged point-of-

view at the intersection of Barshop Blvd. and the frontage road, albeit during the daytime:

One eyewitness also testified that Jones was driving without his headlights on and only

turned them on immediately before the collision.

Finally, two witnesses testified that Jones attempted to flee the scene in his vehicle

but was unable to do so because his vehicle was inoperable. One of these witnesses told

Jones that he could not leave the scene, and the other witness heard Jones respond, “I

2 There were two other possible routes Jones could have taken: he could have been traveling the

correct direction on the frontage road and made a U-Turn onto the exit ramp, or he could have already been traveling the wrong direction on the frontage road when he turned onto the exit ramp.

4 got to get out of here. I got to get out of here.”

Jones acknowledged at trial that he had two beers several hours earlier in the

evening but strenuously disputed that he was intoxicated or that alcohol contributed in

any way to the incident. According to his timeline of events, Jones consumed these two

beers at home while he was having dinner with his family; he later met up with friends at

The Block, a food truck park near the University of Texas at San Antonio; and he spent a

few hours with these friends but did not consume any alcohol during this period. Jones

argued that the collision was nothing more than a tragic yet relatable accident because it

is not uncommon for someone to mistakenly drive the wrong way down a street. On that

score, he called an accident reconstruction expert who testified that there should have

been a one-way sign at the above intersection to apprise Jones that he could not turn left

onto the exit ramp.

Other experts called by Jones testified that the results from the field sobriety tests

and blood draw were not credible. One of those experts testified that it was improper to

administer field sobriety tests to Jones because he had just been involved in a serious

auto accident and was complaining about a head injury. According to that expert, the

results were unreliable because a person with head trauma can exhibit the same clues

that indicate intoxication on the tests. Two other experts testified that the nurse who

conducted the blood draw and the laboratory that tested the sample both made mistakes

that compromised the BAC results.

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