Jose Florentino Ortiz v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 11, 2025
Docket01-23-00961-CR
StatusPublished

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

Opinion

Opinion issued December 11, 2025

In The

Court of Appeals For The

First District of Texas ———————————— NOS. 01-23-00959-CR, 01-23-00960-CR, 01-23-00961-CR ——————————— JOSE FLORENTINO ORTIZ, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 268th District Court Fort Bend County, Texas Trial Court Case Nos. 20-DCR-092408C, 20-DCR-093160A, 20-DCR-093162A

MEMORANDUM OPINION

Jose Florentino Ortiz was charged in three different case numbers with

sexual offenses against children. The cases were consolidated for jury trial. In the

first case, he was found guilty of continuous sexual abuse of a child. See TEX. PENAL CODE § 21.02(b). In the remaining two cases, he was found guilty of

aggravated sexual assault of a child. Id. § 22.021(a).

On appeal, he argues that the trial court erred by denying his motion to

sever. He also argues that the trial court erred by denying his motion to suppress

his statement made after arrest. We affirm.

Background

After an investigation into sexual abuse allegations by his nieces, Ortiz was

arrested in 2024 in Fort Bend County. A few days before the arrest, a Fort Bend

County sheriff coordinated a one-party-consent call with Mary and Susie Oles and

their father.1 Ortiz is the paternal uncle of Mary and Susie. During the call, the

family confronted Ortiz. Ortiz acknowledged he had sexually abused Mary and

Susie and apologized for it. Following his arrest, Ortiz confessed to multiple acts

of sexual abuse against Mary and Susie.

When Nancy Chavez’s mother heard that Ortiz was in jail charged with

sexually abusing Mary and Susie, she asked Nancy, who is also Ortiz’s niece, if

anything happened when she was a child around Ortiz. Nancy told her mother that

Ortiz had sexual intercourse with her.

Ortiz was indicted for continuous sexual abuse of a child, alleging that he

committed two or more acts of sexual abuse against Susie Oles and Nancy Chavez,

1 We refer to the three complainants by the same pseudonyms used during trial. 2 who were younger than fourteen at the time. The remaining two indictments were

for aggravated sexual assault of a child, alleging that Ortiz penetrated Mary Oles

mouth with his sexual organ in 1995 and penetrated her sexual organ with his

finger in 1996. Both allegations occurred when Mary was younger than 14 years

old.

The State consolidated the cases into a single criminal action. Ortiz moved

to sever the cases, and the trial court denied his motion. Ortiz also moved to

suppress his post-arrest statements to authorities, asserting that the statements were

obtained in violation of his constitutional right to an attorney. The trial court

denied the motion to suppress.

Ortiz proceeded to a jury trial. Among other witnesses, Nancy, Susie, Mary,

and Ortiz testified. The testimony included that Ortiz sexually abused the three

complainants for many years when they visited their grandparents’ house. Mary

testified that Ortiz lived with her paternal grandparents. She testified that Ortiz

began abusing her when she was 5 years old. On multiple occasions over the

course of several years, he put his penis in her mouth and his fingers in her vagina.

He began having vaginal intercourse with her when she was about 13. When she

was about 15, she started avoiding family gatherings to hide from Ortiz. She did

not tell anyone about the abuse until years later.

3 Susie testified that Ortiz touched her vagina with his hands and showed her

photographs of his penis from the time she was 7 until the time she was 12. Susie

testified that the abuse happened at her grandparents’ house or while she was a

passenger in Ortiz’s truck.

Once she heard that Susie and Mary had told their parents about years of

sexual abuse, Nancy’s mother asked her daughter if she had experienced abuse. At

that time, Nancy disclosed that she too had been abused by Ortiz when visiting her

grandparents’ house. Nancy testified that she remembered waking up with Ortiz’s

penis inside her vagina. She also described Ortiz putting his hand on her bottom

inside her underwear while they were riding in a truck. She testified that the abuse

happened several times beginning when she was 5 or 6 years old until she was

about 11.

The jury found Ortiz guilty as charged and assessed punishment at 25 years’

imprisonment for continuous sexual abuse of a child and 16 years’ imprisonment

for each case of aggravated sexual assault of a child. The trial court ordered the

sentences to run consecutively. Ortiz appealed.

On appeal, Ortiz argues that the trial court abused its discretion by denying

his motion to sever and by denying his motion to suppress his post-arrest

statements. We affirm.

4 Severance

Ortiz contends that his convictions should be reversed because the trial court

erred by denying his motion to sever. He argues that the three cases against him do

not arise from the same criminal episode and that the trial court erred in finding

that he would not be unfairly prejudiced by joinder. We disagree.

A. Standard of Review and Applicable Law

“A defendant may be prosecuted in a single criminal action for all offenses

arising out of the same criminal episode.” TEX. PENAL CODE § 3.02(a). A

“‘criminal episode’ means, in relevant part, the commission of two or more

offenses, regardless of whether the harm is directed toward or inflicted upon more

than one person” when “the offenses are the repeated commission of the same or

similar offenses.” Id. § 3.01; see Waddell v. State, 456 S.W.3d 366, 370 (Tex.

App.—Corpus Christi 2015, no pet.) (explaining to qualify as same criminal

episode, “it need only be shown that the offenses for which a defendant was

charged and convicted were the repeated commission of the same or similar

offense” and does not require proof that offenses were committed in same or

similar fashion).

There is a two-tiered statutory framework for severance. Diez v. State, 693

S.W.3d 899, 919 (Tex. App.—Austin 2024, pet. ref’d). Generally, severance is

granted to the defendant as a matter of right. See TEX. PENAL CODE § 3.04(a);

5 Hodge v. State, 500 S.W.3d 612, 621 (Tex. App.—Austin 2016, no pet.); see also

Llamas v. State, 12 S.W.3d 469, 470 (Tex. Crim. App. 2000) (describing

defendant’s “absolute discretion” to decide whether to request “mandatory

severance”). In the second tier, if a defendant is being prosecuted for certain

statutorily listed offenses, including aggravated sexual assault of a child and

continuous sexual assault of a child, then the defendant may receive a severance

only after showing that the defendant “would be unfairly prejudiced by a joinder of

offenses” in the same trial. TEX. PENAL CODE § 3.04(c); see also id. § 3.03(b)

(listing offenses for which automatic right to severance does not apply).

Appellate courts review a trial court’s decision to grant or deny a request to

sever for an abuse of discretion. Salazar v. State, 127 S.W.3d 355, 365 (Tex.

App.—Houston [14th Dist.] 2004, pet. ref’d). A trial court’s ruling will only be

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