Jose Angel Ruiz v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 19, 2025
Docket04-24-00204-CR
StatusPublished

This text of Jose Angel Ruiz v. the State of Texas (Jose Angel Ruiz 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 Angel Ruiz v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-24-00204-CR

Jose Angel RUIZ, Appellant

v.

The STATE OF TEXAS, Appellee

From the 187th Judicial District Court, Bexar County, Texas Trial Court No. 2022CR4248A Honorable Stephanie R. Boyd, Judge Presiding

Opinion by: Velia J. Meza, Justice

Sitting: Rebeca C. Martinez, Chief Justice Lori Massey Brissette, Justice Velia J. Meza, Justice

Delivered and Filed: March 19, 2025

AFFIRMED AS MODIFIED

This appeal arises from the conviction of Jose Angel Ruiz relating to his involvement in

the death of a five-year-old child. Ruiz was convicted of serious bodily injury to a child, aggravated

assault with a deadly weapon, and six counts of injury to a child. 1

1 The jury sentenced Ruiz to a term of life imprisonment on the serious bodily injury charge, 20 years on the aggravated assault charge, and 10 years for each of the six injury-to-a-child charges. 04-24-00204-CR

On appeal, Ruiz argues there was (1) insufficient corroboration of accomplice-witness

testimony; and (2) an improper judicial comment on the weight of the evidence.

BACKGROUND

On February 7, 2022, five-year-old M.L. arrived in the emergency room of Texas Vista

Hospital in San Antonio, Texas, in a condition the medical staff would later describe as “level

three unresponsive.” Gustavo Cervantes, an emergency room nurse of sixteen years, immediately

identified that the child was not breathing and had no pulse. Cervantes started chest compressions.

In trying to administer CPR, Cervantes found mashed bananas in the child’s mouth and had to

digitally remove the same to establish an airway. The medical staff also tried to establish IV access,

but found the veins were not “giving return,” meaning that the veins were not giving a return of

blood, indicating a lack of blood circulation. Cervantes also observed M.L.’s skin was ashen. The

medical team declared M.L. dead within fourteen minutes of her arrival at the emergency room.

Medical records admitted at trial showed that M.L. presented to the emergency room with

“generalized bruising all over her body . . . scratches, missing areas of hair, wounds to her feet,

and toenails missing.” Due to the condition of her body, the San Antonio Police Department

(SAPD) and Child Protective Services (CPS) immediately responded to the hospital.

Testimony of Medical Examiners

The State and Defense each called a medical examiner to testify at trial. The State called

Dr. Kimberly Molina while the Defense called Dr. Rajesh Kannan. Both doctors agreed the child

died from complications caused by blunt force injuries. Dr. Kannan performed the autopsy and

wrote the autopsy report. Dr. Molina, as Chief Medical Examiner, reviewed and approved the

autopsy report.

-2- 04-24-00204-CR

According to Dr. Molina, the child had a laceration on the head with accompanying internal

bruising of the scalp, but no significant brain injuries. Dr. Molina testified the child had a small

fracture on the spine in the lower thoracic area. In her opinion, such fractures occur with blunt

force injuries or overextension of the back. Dr. Molina testified that M.L.’s kidneys showed signs

of failure and thus additional microscopic testing of the kidney was conducted, confirming the

existence of myoglobin. Dr. Molina explained that myoglobin is a muscle protein that causes

kidney failure if released into the bloodstream: this disease process is termed rhabdomyolysis, or

“rhabdo” for short. According to Dr. Molina, rhabdo is caused by trauma or overexertion. She

explained that the autopsy found the rhabdo was likely caused by the injuries M.L. sustained. Dr.

Molina explained that rhabdo could pose a “substantial risk of death.”

Dr. Kannan similarly testified the child “suffered trauma . . . extensive . . . from top to

bottom . . . all over the body.” Dr. Kannan conducted a comprehensive study of all tissues and

major organs, including heart, lungs, liver, adrenal, pancreas, thymus, intestines, and kidneys. He

also tested the spleen to look for myoglobin. Dr. Kannan noted the injuries on the child’s mouth

area were showing signs of healing. He observed missing teeth and explained it was uncommon

for a “child to have quite a few teeth missing with overlaying trauma in different stages of healing.”

Dr. Kannan testified the bruises on the child’s scalp appeared “recent.” During direct examination,

the defense inquired into a “cluster of three contusions measuring 1 to 2 centimeters present in

lower left abdomen.” Dr. Kannan explained that those injuries were “some kind of blunt

trauma . . . [a]nd I can’t really tell exact mechanism how it happened.” Overall, however, Dr.

Kannan described the injuries to the child as “soft tissue injuries . . . and not the immediate cause

of death.” Instead, Dr. Kannan concluded “the child was deteriorating for quite a while.” As to the

cause of the child’s death, Dr. Kannan testified the child’s kidneys failed around the time of death

-3- 04-24-00204-CR

as evidenced by the rhabdo finding. Specifically, he explained that “whatever you see on the skin

is affecting the muscles under them.” “[D]ue to the repeated trauma . . . the muscles, over time,

break down,” and small pieces of the muscle escape into the bloodstream causing the kidney to

fail.

Testimony of Child Protective Services

Anthony Adame, a special investigator for the Texas Department of Family and Protective

Services (the Department or DFPS) responded to the hospital for a child death investigation. As

part of his duties for the Department, Adame works alongside law enforcement to document any

evidence of abuse or neglect of a child in the event the department must intervene. Adame

examined and photographed M.L.’s bruises and looked for signs of abuse or neglect. He testified

he counted approximately ten “pinpoints” at the bottom of her feet and noted two toenails missing

on her left foot. Adame documented a pattern of marking on her left leg and thigh with a

distinguished bruising pattern, and severe bruising to the child’s hands and both sides of the child’s

hips. Adame also noted significant bruising that included cuts and abrasions to the child’s chest,

neck, and face. Adame observed M.L. was missing a significant portion of her hair. Lastly, Adame

was present during SAPD’s custodial interview of Ruiz and personally interviewed the child’s

mother, Katrina Mendoza, later that evening. Adame observed J.L.’s forensic interview and

interviewed Ruiz’s neighbors for his part of the investigation.

Julie Rummel, also a Department investigator, responded to the hospital and was

specifically assigned to M.L.’s six-year-old sister, J.L. Rummel saw no bruising on J.L., and noted

the child appeared well-nourished and clean. Rummel was also involved in the inspection of

M.L.’s body in her role as a CPS investigator. She testified she saw “missing teeth, toenails

missing . . . there were little, like thumbtack wounds on the bottom of her feet . . . clumps of hair

-4- 04-24-00204-CR

missing . . . it was very, very bad.” Rummel removed J.L. from Mendoza and set up the child

forensic interview.

Child Forensic Interview of J.L.

J.L. was interviewed at Child Safe by a forensic interviewer, the video of which was

introduced into evidence at trial by the Defense. The interview was conducted several days after

M.L. died and after J.L.

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