Jose Francisco Samayoa v. State

CourtCourt of Appeals of Texas
DecidedJuly 22, 2014
Docket01-13-00538-CR
StatusPublished

This text of Jose Francisco Samayoa v. State (Jose Francisco Samayoa 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
Jose Francisco Samayoa v. State, (Tex. Ct. App. 2014).

Opinion

Opinion issued July 22, 2014

In The

Court of Appeals For The

First District of Texas ———————————— NOS. 01-13-00537-CR & 01-13-00538-CR ——————————— JOSE FRANCISCO SAMAYOA, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 262nd District Court Harris County, Texas Trial Court Case Nos. 1378265, 1378267

MEMORANDUM OPINION

Appellant Jose Francisco Samayoa was convicted by a jury of two counts of

aggravated sexual assault of a disabled individual. See TEX. PENAL CODE ANN.

§ 22.021(a)(2)(C) (West 2011). The jury assessed punishment at 50 years in prison.

In this appeal, Samayoa argues that the evidence was legally insufficient to support his conviction because there was no evidence that he knew the complainant was

incapable, by reason of mental disease or defect, of appreciating the nature of the

act or resisting it. See id. §§ 22.021(c), 22.011(b)(4). We affirm the judgment of

the trial court.

Background

Appellant Jose Francisco Samayoa married a woman named Lucy in 2008.

The complainant in this case is Lucy’s daughter, who at the time of the marriage

was an adult in her early twenties.

Lucy had adopted the complainant when she was a young child. The

complainant had been removed from the custody of her biological parents, who

were related to Lucy, because both suffered from paranoid schizophrenia. When

the complainant entered her adoptive mother’s household at age seven, she

suffered from several developmental impairments. She was unable to speak, groom

herself, eat with a fork and knife, or dress herself. She did not speak her first words

until the age of 10.

The complainant attended school as a special education student, where she

received therapy and life skills training. At the age of 18, a probate court found her

to be “totally incapacitated without the authority to exercise any rights or powers

for herself,” and it appointed Lucy as her guardian.

2 The complainant has been diagnosed with an unspecified communication

disorder, autism, pervasive development disorder, and moderate to high mental

retardation. The evidence at trial showed that she interacts politely with others, and

she can perform simple tasks such as making a sandwich, putting on her clothes,

and grooming herself. However, she cannot live independently, as she cannot do

other essential tasks without supervision, such as using a stove or oven, seeking aid

in a medical emergency, navigating a city bus system, or shopping for groceries.

Accordingly, because of her disability, as a young adult the complainant lived with

her mother Lucy.

Samayoa married Lucy and began residing with her family shortly after the

complainant finished high school at age 22. Lucy testified that Samayoa observed

her helping the complainant with simple tasks that she could not perform on her

own, such as cooking on the stove, and that they discussed her disability.

Lucy had a cleaning business, with which Samayoa and the complainant

sometimes assisted. Often, Samayoa and the complainant were alone together to

clean an office building. On many such occasions, Samayoa would have sex with

the complainant. He also had intercourse with her at home. The sexual encounters

at the work sites and at home began when the complainant was 23 years old, and

they continued over a period of several years.

3 In April 2012, Lucy went to a conference out of town and left the

complainant at a relative’s home. Samayoa later picked up the complainant and

had intercourse with her. The next day, the complainant sent Lucy a text message,

informing her that she had been having sex with Samayoa. Lucy then immediately

arranged for the complainant to be taken to a police station.

An investigation ensued and Samayoa was indicted by a grand jury for

aggravated sexual assault. At trial he admitted to having intercourse with the

complainant. Lucy testified about the complainant’s disabilities and Samayoa’s

history with the family. In closing argument, defense counsel argued that the

complainant did not satisfy the relevant legal definition of a “disabled” person and

that Samayoa did not know that she was incapable of consent. The jury found

Samayoa guilty and sentenced him to 50 years in prison. He timely filed notice of

appeal.

Analysis

In one appellate issue, Samayoa argues that the evidence was legally

insufficient to support his conviction because there was no evidence that at the

times he had sex with the complainant, he knew that as a result of mental disease

or defect she was incapable of appraising the nature of the act or resisting it.

“In determining whether the evidence is legally sufficient to support a

conviction, a reviewing court must consider all of the evidence in the light most

4 favorable to the verdict and determine whether, based on that evidence and

reasonable inferences therefrom, a rational fact finder could have found the

essential elements of the crime beyond a reasonable doubt.” Gear v. State, 340

S.W.3d 743, 746 (Tex. Crim. App. 2011) (citing Jackson v. Virginia, 443 U.S. 307,

318–19, 99 S. Ct. 2781, 2788–89 (1979)). “Each fact need not point directly and

independently to the guilt of the appellant, as long as the cumulative force of all

the incriminating circumstances is sufficient to support the conviction.” Hooper v.

State, 214 S.W.3d 9, 13 (Tex. Crim. App. 2007). “Circumstantial evidence is as

probative as direct evidence in establishing the guilt of an actor, and circumstantial

evidence alone can be sufficient to establish guilt.” Id. When reviewing the

evidence, an appellate court must defer to the jury’s determinations of credibility

and the weight appropriate to different pieces of evidence. See Williams v. State,

235 S.W.3d 742, 750 (Tex. Crim. App. 2007).

Except for offenses involving a child, in order for a person to be guilty of

aggravated sexual assault, the sexual contact must have occurred without the

consent of the complainant. See TEX. PENAL CODE ANN. §§ 22.011(a), 22.021. If a

person knows “that as a result of mental disease or defect the other person is at the

time of the sexual assault incapable either of appraising the nature of the act or of

resisting it,” then the sexual contact is deemed to occur “without the consent of the

other person.” Id. § 22.011(b)(4).

5 Considering the appellate record in this case, we do not agree that the

evidence was legally insufficient to establish that Samayoa knew that the

complainant, by reason of mental disease or defect, was incapable of appraising the

nature of the act or of resisting it. Lucy testified that she spoke with Samayoa

about the complainant’s condition. There was also ample circumstantial evidence

from which the jury could have inferred that Samayoa harbored the necessary

mens rea. Proof of a defendant’s state of mind “almost invariably depends on

circumstantial evidence.” Tottenham v. State, 285 S.W.3d 19, 28 (Tex. App.—

Houston [1st Dist.] 2009, pet. ref’d).

It was undisputed that Samayoa lived in the same household with the

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Williams v. State
235 S.W.3d 742 (Court of Criminal Appeals of Texas, 2007)
Martinez v. State
634 S.W.2d 929 (Court of Appeals of Texas, 1982)
Harris v. State
474 S.W.2d 706 (Court of Criminal Appeals of Texas, 1972)
Sanchez v. State
479 S.W.2d 933 (Court of Criminal Appeals of Texas, 1972)
Tottenham v. State
285 S.W.3d 19 (Court of Appeals of Texas, 2009)
Smith v. State
555 S.W.2d 747 (Court of Criminal Appeals of Texas, 1977)
Gear v. State
340 S.W.3d 743 (Court of Criminal Appeals of Texas, 2011)

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