Jose Alejandro Casas v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMay 31, 2023
Docket08-22-00109-CR
StatusPublished

This text of Jose Alejandro Casas v. the State of Texas (Jose Alejandro Casas 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
Jose Alejandro Casas v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS

JOSE ALEJANDRO CASAS, § No. 08-22-00109-CR

Appellant, § Appeal from the

v. § 34th Judicial District Court

THE STATE OF TEXAS, § of El Paso County, Texas

Appellee. § (TC# 20190D04554)

OPINION

BACKGROUND

In five issues, Appellant Jose Alejandro Casas, challenges his conviction of murder.

TEX. PENAL CODE ANN. 19.02(c). For the reasons that follow, we affirm.

Factual Background

On July 13, 2019, Santana Castro (Santana), was found deceased in her home. An autopsy

was performed, and the deputy medical examiner concluded Santana died of a gunshot wound to

the head and determined the manner of death as a homicide. The deputy medical examiner testified

there was no evidence to suggest the manner of death was a suicide.

In the early afternoon on the day of the murder, Santana’s mother left the home she shared

with Santana and Santana’s brother, Raymond Castro (Raymond). As Raymond was getting ready to shower, Santana and Appellant walked into the house through the front door. Shortly after,

Raymond, Santana, and Appellant, smoked a marijuana joint together inside Santana’s car, which

was parked at the house. Appellant and Santana were dating at the time, and Raymond recalled

that “the energy in the car seemed a bit off[.]” After they finished smoking, Santana and Appellant

went inside the house together, and Raymond went inside to his room. Raymond proceeded to

leave the house to run some errands, but before he left, he asked Santana if she was okay. Santana

said she was. Raymond then left the house and returned at around 4 p.m.

When he entered and walked through the house, Santana’s bedroom door was wide open,

and he saw Santana’s body. It was not initially apparent to Raymond that Santana had been shot

or that she was deceased, until he saw her brain matter on the floor. No one else was in the house

at the time, and according to Raymond, the last person with Santana was Appellant.

At trial, a total of 25 witnesses testified, ranging from several of Santana’s family members

and friends, the deputy medical examiner who performed Santana’s autopsy, several responding

officers, detectives, and investigators who worked on the case, along with proffered firearm and

crime scene experts. The State’s theory was that in the totality of the circumstances, there was

sufficient evidence to prove, beyond a reasonable doubt, that Appellant murdered Santana. The

defense presented several theories—1) Santana committed suicide, but if jury found that she did

not commit suicide, then 2) her brother Raymond killed her, but if the jury found that the

aforementioned did not occur, then either 3) Santana must have shot herself in an accidental

discharge, or 4) her brother Raymond accidentally shot her.

Procedural Background

Appellant was charged by indictment with murder, alleged to have occurred in El Paso

County, Texas, on or about July 13, 2019. Trial began on May 2, 2022 and concluded on June 14,

2 2022. The jury found Appellant guilty and assessed punishment at 47 years’ confinement in the

Texas Department of Criminal Justice, Institutional Division. This appeal followed.

DISCUSSION

In five issues, Appellant challenges his conviction of murder. In Issues One and Two,

Appellant argues the State failed to prove venue and that the offense occurred in the State of Texas.

In Issue Three, Appellant claims he received an unfair trial due to alleged prosecutorial

misconduct. In Issue Four, Appellant challenges the admission of evidence. Finally, in Issue

Five—raised in a supplemental brief—Appellant claims the trial judge’s bias deprived him of due

process and a fair trial. We affirm.

VENUE

In Issues One and Two, Appellant challenges venue. In Issue One, Appellant claims the

State failed to prove venue in El Paso County. In Issue Two, Appellant alleges the State failed to

prove the offense occurred in the State of Texas. We disagree.

Standard of Review and Applicable Law

Failure to prove venue in the county of prosecution constitutes reversible error. Lozano v.

State, 958 S.W.2d 925, 929 (Tex. App.—El Paso 1997, no pet.). However, venue is not a

“criminative fact” and thus does not constitute an element of the offense. Id. Accordingly, venue

need not be proved beyond a reasonable doubt, but rather, by a preponderance of the evidence. Id.

Proof of venue may be established by either direct or circumstantial evidence. Id.

Rule 44.2 of the Texas Rules of Appellate Procedure establishes that, “Unless . . . disputed

in the trial court, or unless the record affirmatively shows the contrary, the court of appeals must

presume . . . that venue was proved in the trial court.” TEX. R. APP. P. 44.2(c)(1). Accordingly, as

a threshold matter, a challenge to proof of venue for the first time on appeal will not be entertained.

3 See Puryear v. State, 428 S.W.2d 345, 347 (Tex. Crim. App. 1968) (overruling appellant’s

contention that the State failed to prove the offense occurred in Texas and failed to prove venue

because no issue was made as to venue in the court below, and the indictment was returned and

trial was had in county of conviction); see also Carpenter v. State, 333 S.W.2d 391, 393

(Tex. Crim. App. 1960) (contention that venue was not proved “was raised for the first time after

verdict, and this Court will presume that venue was proved.”).

Analysis

Appellant claims he twice timely moved for a directed verdict of acquittal, thus challenging

venue at trial. Appellant is misguided. In the first instance, Appellant requested a directed verdict:

Your Honor, at this time the defense would make a motion for a directed verdict in this matter. We do not believe that the case -- that the State has made its case to prove what it has alleged in the indictment, Your Honor. We do not believe that there’s sufficient evidence that has been presented to the Court to prove its case beyond a reasonable doubt. We do not believe that the State has proven its case with each and every element of the indictment, Your Honor. And for that reason, Your Honor, we’d ask for a directed verdict, Your Honor.

In the second instance, Appellant renewed his request for a directed verdict: “We will renew our -

- is it at this time that we should renew our motion for a directed verdict[.]”

It is apparent Appellant did not challenge venue in either of these two instances—his

motion and renewed motion for directed verdict. Furthermore, our independent review of the

record, outside of these two instances, shows Appellant did not once challenge venue, by verbal

or written motion, or otherwise. Appellant produced no evidence to suggest venue in El Paso

County was improper. The case was indicted in El Paso County, and the indictment specifically

alleged:

[O]n or about the 13th day of July, 2019 . . . in the County of El Paso and State of Texas, JOSE CASAS, hereinafter referred to as Defendant, . . . [d]id then and there

4 intentionally or knowingly cause the death of an individual, namely, SANTANA CASTRO, by shooting SANTANA CASTRO with a firearm[.]

The trial was thereafter held in El Paso County, Texas, and Appellant was convicted in El Paso

County, Texas.

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Related

Darden v. Wainwright
477 U.S. 168 (Supreme Court, 1986)
Wead v. State
129 S.W.3d 126 (Court of Criminal Appeals of Texas, 2004)
Saxton v. State
804 S.W.2d 910 (Court of Criminal Appeals of Texas, 1991)
Lozano v. State
958 S.W.2d 925 (Court of Appeals of Texas, 1997)
Torres v. State
71 S.W.3d 758 (Court of Criminal Appeals of Texas, 2002)
Koller v. State
518 S.W.2d 373 (Court of Criminal Appeals of Texas, 1975)
Coleman v. State
632 S.W.2d 616 (Court of Criminal Appeals of Texas, 1982)
Osbourn v. State
92 S.W.3d 531 (Court of Criminal Appeals of Texas, 2002)
Jimenez v. State
240 S.W.3d 384 (Court of Appeals of Texas, 2007)
Melgar v. State
236 S.W.3d 302 (Court of Appeals of Texas, 2007)
Colburn v. State
966 S.W.2d 511 (Court of Criminal Appeals of Texas, 1998)
Rogers v. State
725 S.W.2d 350 (Court of Appeals of Texas, 1987)
Ontiveros v. State
890 S.W.2d 919 (Court of Appeals of Texas, 1994)
Carpenter v. State
333 S.W.2d 391 (Court of Criminal Appeals of Texas, 1960)
Barshaw v. State
342 S.W.3d 91 (Court of Criminal Appeals of Texas, 2011)
Tienda, Ronnie Jr.
358 S.W.3d 633 (Court of Criminal Appeals of Texas, 2012)
Puryear v. State
428 S.W.2d 345 (Court of Criminal Appeals of Texas, 1968)
Daniels v. State
708 S.W.2d 532 (Court of Appeals of Texas, 1986)
Perkins v. State
905 S.W.2d 452 (Court of Appeals of Texas, 1995)

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