Jorge Ayala v. State

CourtCourt of Appeals of Texas
DecidedAugust 18, 2005
Docket13-04-00380-CR
StatusPublished

This text of Jorge Ayala v. State (Jorge Ayala 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
Jorge Ayala v. State, (Tex. Ct. App. 2005).

Opinion

                                    NUMBER 13-04-380-CR

                                 COURT OF APPEALS

                     THIRTEENTH DISTRICT OF TEXAS

                         CORPUS CHRISTI B EDINBURG

JORGE AYALA,                                                                                Appellant,

                                                             v.

THE STATE OF TEXAS,                                                                    Appellee.

                    On appeal from the 117th District Court

                                        of Nueces County, Texas.

                                M E M O R A N D U M   O P I N I O N

     Before Chief Justice Valdez and Justices Hinojosa and Rodriguez

      Opinion by Chief Justice Valdez


Appellant, Jorge Ayala, was convicted of burglary of a habitation with intent to commit aggravated robbery.  Tex. Pen. Code Ann. _ 30.02 (Vernon 2003).  He was sentenced to sixty years= imprisonment, and the court ordered that the sentence be stacked on a twenty-year sentence appellant had previously received for an unrelated offense.  On appeal, appellant contends (1) the trial court erred by admitting into evidence an impermissibly suggestive pretrial photo lineup of appellant, and (2) the sixty-year sentence and the order stacking the sentence on a prior twenty-year sentence is cruel and unusual, and disproportionate to the crime committed, all in violation of the Eighth and Fourteenth Amendments to the United States Constitution.  We affirm.

I. Facts

On the day following the incident leading to appellant=s arrest, Mrs. Ward, one of the victims, positively identified appellant in a pretrial photo lineup.  The picture showed appellant wearing a red v-neck shirt.  No other person in the photo lineup wore a v-neck shirt.  Mrs. Ward testified she picked out appellant within seconds and that his bony facial features led her to that conclusion.  Appellant was found guilty by a jury and elected to have the court assess punishment.  The court considered a variety of factors regarding punishment and sentenced appellant to sixty years with time to commence after a prior twenty-year sentence ceased to operate.

II. Impermissibly Suggestive Photo Line-Up

A. Standard of Review


When reviewing a trial court=s ruling on the admissibility of an identification which has been attacked as the product of an impermissibly suggestive pretrial identification procedure, the test is whether, considering the totality of circumstances, Athe photographic identification procedure was so impermissibly suggestive as to give rise to a very substantial likelihood of irreparable misidentification.@  Loserth v. State, 963 S.W.2d 770, 772 (Tex. Crim. App. 1998) (citing Simmons  v. United States, 390 U.S. 377, 384 (1968)); Palma v. State, 76 S.W.3d 638, 643 (Tex. App.BCorpus Christi 2002, pet. ref=d).  The goal of the review is to determine the reliability of the identification procedure.  See Loserth, 963 S.W.2d at 772. 

The following five non-exclusive factors should be Aweighed against the corrupting effect of any suggestive identification procedure in assessing reliability under the totality of circumstances@: (1) the opportunity of the witness to view the criminal at the time of the crime; (2) the witness=s degree of attention; (3) the accuracy of the witness=s prior description of the criminal; (4) the level of certainty demonstrated by the witness at confrontation; and (5) the length of time between the crime and the confrontation.  Id. (citing Neil v. Biggers, 409 U.S. 188, 199 (1972)).  Each of the individual Biggers factors are historical facts, and should be viewed deferentially, in the light most favorable to the trial court=s ruling.  Id.

The application of the factors, and thus, the Aultimate conclusions as to whether the facts as found state a constitutional violation, is a mixed question of law and fact.@  Id. at 773.  Therefore, we review the trial court=s application of the factors de novo.  Id. at 773-74.  When a trial court does not make express findings of historical facts, the facts are viewed in a light favorable to the court=s ruling.  Id. at 774.

B. Analysis


Here, appellant=

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Related

Simmons v. United States
390 U.S. 377 (Supreme Court, 1968)
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Harmelin v. Michigan
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Jorge Ayala v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jorge-ayala-v-state-texapp-2005.