Joseph Francis Weaver v. State

CourtCourt of Appeals of Texas
DecidedNovember 21, 2007
Docket10-06-00326-CR
StatusPublished

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Bluebook
Joseph Francis Weaver v. State, (Tex. Ct. App. 2007).

Opinion

IN THE

TENTH COURT OF APPEALS

 

No. 10-06-00326-CR

Joseph Francis Weaver,

                                                                                    Appellant

 v.

The State of Texas,

                                                                                    Appellee


From the 367th District Court

Denton County, Texas

Trial Court No. F-2005-1245-E

MEMORANDUM  Opinion


            Joseph Francis Weaver was charged with one count of indecency with a child and three counts of aggravated sexual assault.  The jury convicted Weaver of the indecency count, for which he received twenty years in prison, and one aggravated sexual assault count, for which he received ninety-nine years in prison.  In two points of error, Weaver challenges: (1) the denial of his motion to suppress; and (2) the admission of certain testimony.  We affirm.

MOTION TO SUPPRESS

            In his first point, Weaver argues that the trial court erred by denying his motion to suppress tape recordings of telephone conversations between Weaver and the victim, C.V., because: (1) there was no vicarious consent; and (2) there is a reasonable expectation of privacy in conversations conducted via speakerphone.

Standard of Review

We apply a bifurcated standard of review to the denial of a motion to suppress.  See Haas v. State, 172 S.W.3d 42, 49 (Tex. App.—Waco 2005, pet ref’d).  First, we review the denial for abuse of discretionSee Oles v. State, 993 S.W.2d 103, 106 (Tex. Crim. App. 1999).  Second, we conduct a de novo review of the law as applied to the facts.  See Haas, 172 S.W.3d at 49; see also Carmouche v. State, 10 S.W.3d 323, 327 (Tex. Crim. App. 2000);  Oles, 993 S.W.2d at 106.  The court’s findings receive “almost total deference” and absent specific findings, we review the evidence in the “light most favorable” to the ruling.  Haas, 172 S.W.3d at 49; Carmouche, 10 S.W.3d at 327-328.  The ruling will be affirmed if “reasonably supported by the record” and correct on any applicable legal theory.  Romero v. State, 800 S.W.2d 539, 543 (Tex. Crim. App. 1990); Cisneros v. State, 165 S.W.3d 853, 856 (Tex. App.—Texarkana 2005, no pet.).   

Analysis

A person commits an offense if he “intentionally intercepts, endeavors to intercept, or procures another person to intercept or endeavor to intercept a wire, oral, or electronic communication,” unless the “person is a party to the communication” or “one of the parties to the communication has given prior consent.”  Tex. Pen. Code Ann. § 16.02(b)(1); (c)(4)(A)-(B) (Vernon Supp. 2007).

The record contains four audio tapes recorded by C.V.’s mother Rosemary, Weaver’s “common law wife,” of conversations between Weaver and C.V.  Weaver filed a motion to suppress the tapes on grounds that they were made without either his or C.V.’s consent.  At a hearing on the motion, Weaver admitted having telephone conversations with C.V., but denied consenting to the recording of these conversations.  C.V. testified that she consented to the recording of two tapes and the remaining tapes were made while she was speaking to Weaver via speakerphone.  During these conversations, she and Weaver discussed their relationship and ways to conceal the relationship from Rosemary.  C.V. believed that Rosemary made the tapes to obtain proof of C.V.’s relationship with Weaver.  The State argued that the tapes were admissible because a parent may give vicarious consent to record a child’s telephone conversations and that there is no legitimate expectation of privacy in speakerphone conversations.  The trial court denied Weaver’s motion.[1]

Vicarious Consent

Until recently, “no Texas cases have addressed a parent’s ability to vicariously consent to the recording of a child’s telephone conversations.”  Alameda v. State, No. PD-0231-06, 2007 Tex. Crim. App. Lexis 868, at *9 (Tex. Crim. App. June 27, 2007).  The parties cite to two cases, Pollock v. Pollock, a Sixth Circuit case, and Alameda v State, a Fort Worth Court of Appeals case, which discuss the doctrine of vicarious consent in the context of the parent/child relationship.[2]

In Pollock, Samuel and Laura Pollock brought an action against Sandra Pollock, alleging that Sandra violated the federal wiretapping statute when she recorded conversations between Samuel and their minor daughter Courtney, and between Laura, Samuel’s wife, and Courtney.  See 154 F.3d 601, 602 (6th Cir. 1998).  Sandra argued that “she ‘vicariously consented’ to the recording on behalf of Courtney, a minor child in her custody, because she was concerned that Samuel was emotionally abusing Courtney.”  Id. at 603.  The Sixth Circuit held that “as long as the guardian has a good faith, objectively reasonable basis for believing that it is necessary and in the best interest of the child to consent on behalf of his or her minor child to the taping of telephone conversations, the guardian may vicariously consent on behalf of the child to the recording.”[3]

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Related

Martin v. State
173 S.W.3d 463 (Court of Criminal Appeals of Texas, 2005)
Shuffield v. State
189 S.W.3d 782 (Court of Criminal Appeals of Texas, 2006)
Elder v. State
132 S.W.3d 20 (Court of Appeals of Texas, 2004)
Carmouche v. State
10 S.W.3d 323 (Court of Criminal Appeals of Texas, 2000)
Alameda v. State
181 S.W.3d 772 (Court of Appeals of Texas, 2005)
Lane v. State
151 S.W.3d 188 (Court of Criminal Appeals of Texas, 2004)
Cisneros v. State
165 S.W.3d 853 (Court of Appeals of Texas, 2005)
Rachal v. State
917 S.W.2d 799 (Court of Criminal Appeals of Texas, 1996)
Oles v. State
993 S.W.2d 103 (Court of Criminal Appeals of Texas, 1999)
Peoples v. CCA Detention Centers
127 S. Ct. 664 (Supreme Court, 2006)
Haas v. State
172 S.W.3d 42 (Court of Appeals of Texas, 2005)
Romero v. State
800 S.W.2d 539 (Court of Criminal Appeals of Texas, 1990)
Anderson v. State
717 S.W.2d 622 (Court of Criminal Appeals of Texas, 1986)

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Joseph Francis Weaver v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-francis-weaver-v-state-texapp-2007.