Joseph Bebout West, Jr. v. the State of Texas

CourtTexas Court of Appeals, 6th District (Texarkana)
DecidedApril 27, 2026
Docket06-25-00139-CR
StatusPublished

This text of Joseph Bebout West, Jr. v. the State of Texas (Joseph Bebout West, Jr. v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 6th District (Texarkana) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph Bebout West, Jr. v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

In the Court of Appeals Sixth Appellate District of Texas at Texarkana

No. 06-25-00139-CR

JOSEPH BEBOUT WEST, JR., Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the County Court at Law No. 1 Gregg County, Texas Trial Court No. 2024-1026

Before Stevens, C.J., van Cleef and Rambin, JJ. Memorandum Opinion by Justice van Cleef MEMORANDUM OPINION

A Gregg County jury found Appellant, Joseph Bebout West, Jr., guilty of assault, family

violence, and the trial court sentenced him to one year of incarceration. See TEX. PENAL CODE

ANN § 22.01(a)(1). West argues that (1) the trial court abused its discretion by denying his

motion for new trial on the basis that he was denied an unbiased jury, and (2) there was jury-

charge error. Because we find that West forfeited his right to complain about the juror and that

there was no jury-charge error, we affirm.

I. Motion for New Trial

We “review[] a trial court’s denial of a motion for new trial for an abuse of discretion.”

Burch v. State, 541 S.W.3d 816, 820 (Tex. Crim. App. 2017). We will “revers[e] only if no

reasonable view of the record could support the trial court’s ruling.” Id. This deferential

standard of review requires us to “view the evidence in the light most favorable to the trial

court’s ruling.” Id. “In determining whether the trial court abused its discretion, [we] must not

substitute [our] own judgment for that of the trial court, and [we] must uphold the trial court’s

ruling if it is within the zone of reasonable disagreement.” Id.; Hicks v. State, 606 S.W.3d 308,

314–15 (Tex. App.—Houston [1st Dist.] 2020, pet. ref’d) (citing Colyer v. State, 428 S.W.3d

117, 122 (Tex. Crim. App. 2014) (“We do not substitute our judgment for that of the trial court;

rather, we decide whether the trial court’s decision was arbitrary or unreasonable.” (quoting

Holden v. State, 201 S.W.3d 761, 763 (Tex. Crim. App. 2006)))).

As our sister court in Hicks explained,

The Sixth Amendment guarantees the assistance of counsel and the right to a trial before an impartial jury. Franklin v. State, 138 S.W.3d 351, 354 (Tex. Crim. 2 App. 2004); Linnell v. State, 935 S.W.[2]d 426, 428 (Tex. Crim. App. 1996); see U.S. CONST. amend. VI (“In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed . . . and to have the Assistance of Counsel for his defence.”). Part of this constitutional guarantee includes “adequate voir dire to identify unqualified jurors.” Franklin, 138 S.W.3d at 354 (citing Morgan v. Illinois, 504 U.S. 719, 729, 112 S.Ct. 2222, 119 L.Ed.2d 492 (1992)). The Court of Criminal Appeals has also “consistently held that essential to the Sixth Amendment guarantees of the assistance of counsel and trial before an impartial jury ‘is the right to question veniremembers in order to intelligently exercise peremptory challenges and challenges for cause.’” Id. (quoting Raby v. State, 970 S.W.2d 1, 10 (Tex. Crim. App. 1998) (Baird, J., concurring and dissenting)). “The voir dire process is designed to insure, to the fullest extent possible, that an intelligent, alert, disinterested, impartial, and truthful jury will perform the duty assigned to it.” Armstrong v. State, 897 S.W.2d 361, 363 (Tex. Crim. App. 1995) (per curiam).

Hicks, 606 S.W.3d at 315. The Houston court went on to explain,

With the exception of the second, third, and fourth challenges for cause listed in article 35.16—that the prospective juror has been convicted of misdemeanor theft or a felony; the prospective juror is under indictment or other accusation for misdemeanor theft or a felony; and the prospective juror is insane—the remaining challenges for cause are not absolute disqualifications. See Webb v. State, 232 S.W.3d 109, 112 (Tex. Crim. App. 2007) (addressing article 35.16(a)(7), concerning prospective juror’s service on grand jury that returned indictment against defendant); Vera v. State, 496 S.W.3d 293, 295 (Tex. App.—San Antonio 2016, pet. ref’d) (“With the exception of three specific grounds for disqualification, the disqualification grounds listed in article 35.16 may be waived.”); see also TEX. CODE CRIM. PROC. ANN. art. 35.19 (entitled “absolute disqualification” and providing that, even if parties agree, prospective juror may not be impaneled if subject to second, third, or fourth challenges listed in article 35.16). “All grounds for challenge for cause may be forfeited,” and a challenge for cause “is forfeited if not made.” Webb, 232 S.W.3d at 112. A party’s failure to question the prospective jurors on that subject “constitutes a forfeiture of the right to complain thereafter.” Id.; Ex parte Perez, 525 S.W.3d 325, 339 (Tex. App.—Houston [14th Dist.] 2017, no pet.) (stating that “challenge to a juror based on a non-absolute disqualification, such as county residence, is a forfeitable right, not a waivable right” and all party has to do forfeit such challenge is “remain silent”); Vera, 496 S.W.3d at 295 (“[W]ith three exceptions not applicable here, the failure to make a timely objection to a juror’s

3 qualifications under article 35.16 waives the right to challenge those qualifications.”).

Hicks, 606 S.W.3d at 316–17 (alteration in original).

“[D]efense counsel has an obligation to ask questions calculated to bring out that

information which might be said to indicate a juror’s inability to be impartial and truthful.”

Armstrong, 897 S.W.2d at 363–64. Without defense counsel asking such questions, the juror did

not withhold any information. See Hicks, 606 S.W.3d at 317; Armstrong, 897 S.W.2d at 364; see

also Franklin, 138 S.W.3d at 355–56 (“Under Texas law, the defendant must show that the juror

withheld material information during voir dire, and the information is withheld despite due

diligence exercised by the defendant.” (emphasis added)); Gonzales v. State, 3 S.W.3d 915, 916–

17 (Tex. Crim. App. 1999) (noting “that error occurs where ‘a prejudiced or biased juror is

selected without fault or lack of diligence on the part of defense counsel, such counsel acting in

good faith on the juror’s responses and having no knowledge of their inaccuracy’” (quoting

Brandon v. State, 599 S.W.2d 567, 577 (Tex. Crim. App. 1979))); White v. State, 181 S.W.3d

514, 518 (Tex. App.—Texarkana 2005), aff’d, 225 S.W.3d 571 (Tex. Crim. App. 2007)

(considering whether defense counsel “used due diligence in eliciting the withheld information

omitted by the juror or jurors during voir dire”).

“There is a ‘necessity’ that defense counsel ‘ask during voir dire all of the relevant

statutory questions to determine whether a juror may be disqualified.’” Hicks, 606 S.W.3d at

317–18 (quoting Webb, 232 S.W.3d at 113 (citing Stillwell v. State, 466 S.W.3d 908, 913 (Tex.

App.—Fort Worth 2015, no pet.) (“stating that attorneys have duty ‘to determine capability or

fitness of the jurors during voir dire’”))).

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Related

Morgan v. Illinois
504 U.S. 719 (Supreme Court, 1992)
Ngo v. State
175 S.W.3d 738 (Court of Criminal Appeals of Texas, 2005)
Franklin v. State
138 S.W.3d 351 (Court of Criminal Appeals of Texas, 2004)
Miller v. State
312 S.W.3d 209 (Court of Appeals of Texas, 2010)
Raby v. State
970 S.W.2d 1 (Court of Criminal Appeals of Texas, 1998)
White v. State
181 S.W.3d 514 (Court of Appeals of Texas, 2006)
Holden v. State
201 S.W.3d 761 (Court of Criminal Appeals of Texas, 2006)
Woodfox v. State
742 S.W.2d 408 (Court of Criminal Appeals of Texas, 1987)
Rodriguez v. State
758 S.W.2d 787 (Court of Criminal Appeals of Texas, 1988)
Juarez v. State
308 S.W.3d 398 (Court of Criminal Appeals of Texas, 2010)
Swearingen v. State
270 S.W.3d 804 (Court of Appeals of Texas, 2008)
Brandon v. State
599 S.W.2d 567 (Court of Criminal Appeals of Texas, 1980)
Webb v. State
232 S.W.3d 109 (Court of Criminal Appeals of Texas, 2007)
Dyson v. State
672 S.W.2d 460 (Court of Criminal Appeals of Texas, 1984)
White v. State
225 S.W.3d 571 (Court of Criminal Appeals of Texas, 2007)
Allen v. State
253 S.W.3d 260 (Court of Criminal Appeals of Texas, 2008)
Granger v. State
3 S.W.3d 36 (Court of Criminal Appeals of Texas, 1999)
Gonzales v. State
3 S.W.3d 915 (Court of Criminal Appeals of Texas, 1999)
Neal v. State
256 S.W.3d 264 (Court of Criminal Appeals of Texas, 2008)
Shaw v. State
243 S.W.3d 647 (Court of Criminal Appeals of Texas, 2007)

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Joseph Bebout West, Jr. v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-bebout-west-jr-v-the-state-of-texas-txctapp6-2026.