Juan Manuel Mendoza v. State

CourtCourt of Appeals of Texas
DecidedDecember 28, 2007
Docket04-06-00636-CR
StatusPublished

This text of Juan Manuel Mendoza v. State (Juan Manuel Mendoza 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
Juan Manuel Mendoza v. State, (Tex. Ct. App. 2007).

Opinion

                                        MEMORANDUM OPINION

                                                             No. 04-06-00636-CR

                                                         Juan Manuel MENDOZA,

                                                                      Appellant

                                                                             v.

                                                            The STATE of Texas,

                                                                       Appellee

                            From the 79th Judicial District Court, Jim Wells County, Texas

                                                    Trial Court No. 05-04-11609-CR

                                         Honorable Richard C. Terrell, Judge Presiding

Opinion by:        Rebecca Simmons, Justice

Sitting:               Catherine Stone, Justice

Phylis J. Speedlin, Justice

Rebecca Simmons, Justice

Delivered and Filed:  December 28, 2007

AFFIRMED

            Appellant Juan Manuel Mendoza was convicted by a jury for the murder of his wife, Sandra Zavaleta, and the trial court sentenced Mendoza to confinement in the Institutional Division of the Texas Department of Criminal Justice for a period of twenty-five years.  Mendoza maintains the shooting was accidental and raises issues relating to insufficient evidence, erroneous admission of evidence, improper jury argument and ineffective assistance of counsel.  We affirm the judgment of the trial court.

Factual Background

On February 4, 2004, at approximately 3:09 a.m., a 911 call to the Jim Wells County Sheriff’s Department reported that Sandra Zavaleta, Appellant Mendoza’s wife, had been accidentally shot in the face.  The 911 dispatcher testified the caller explained that he was cleaning a firearm when Zavaleta “tried to grab the gun, and it shot her in the face.”

Two officers arrived at the Mendoza home where they found Zavaleta, on the bed, deceased.  Mendoza described the circumstances surrounding the incident to Officer Joe Martinez[1] explaining that “he was walking out of the bathroom with the weapons in his hand, and that the handgun accidentally discharged and struck [Zavaleta] in the face.”  Captain Enrique Saenz transported Mendoza to the Jim Wells County Sheriff=s Office, where Mendoza provided a written statement regarding the shooting.

Admission of Evidence

Mendoza asserts the trial court erred in admitting the 911 recording into evidence.  We review a trial court’s ruling on the admissibility of evidence under an abuse of discretion standard.  Weatherred v. State, 15 S.W.3d 540, 542 (Tex. Crim. App. 2000).  As long as the trial court’s ruling was within the zone of reasonable disagreement, we will not interfere with the ruling. Id.

A.        The 911 Recording

Mendoza contends the trial court abused its discretion by admitting the 911 recording based on the State’s failure to either identify the caller or show a proper chain of custody.  Although the Texas Rules of Evidence do not specifically define the term “chain of custody,” Rule 901(a) provides that, for admissibility purposes, the authentication or identification of an item is satisfied by evidence that is sufficient to support a finding that the item in question is what its proponent claims.  Tex. R. Evid. 901(a); Silva v. State, 989 S.W.2d 64, 67 (Tex. App.CSan Antonio 1998, pet. ref’d) (explaining that chain of custody goes to weight and not to admissibility).  Evidence may be authenticated or identified by different methods, including testimony by a witness with knowledge that “a matter is what it is claimed to be.”  Tex. R. Evid. 901(b)(1); see also Angleton v. State, 971 S.W.2d 65, 67-68 (Tex. Crim. App. 1998).  The court properly admits evidence when a reasonable juror could find that the evidence has been authenticated or identified.  See Pondexter v. State, 942 S.W.2d 577, 586 (Tex. Crim. App. 1996).

Here, the 911 dispatcher testified that, although he neither made the recordings nor retained custody of the recordings, the two recordings were true and accurate representations of the calls he received on the evening of the incident.  The evidence supports the trial court’s determination that Rule 901 was satisfied.  Tex. R. Evid. 901; see Angleton, 971 S.W.2d at 67-68 (upholding admission of audiotape when a witness, with knowledge, testified that the enhanced recording produced at trial was an accurate copy of the relevant contents of the original recording).  Accordingly, the trial court did not abuse its discretion in admitting the testimony.

B.        Mendoza’s Statement

Mendoza next contends that his statement was inadmissible because it was not recorded in accordance with Article 38.22 of the Texas Code of Criminal Procedure.  Tex. Code Crim. Proc. Ann. art. 38.22 (Vernon 2005).  Article 38.22 sets forth the necessary requirements for admissibility of a written statement.  See id.  To comply with Article 38.22, Section 2, the face of the written statement must show the accused (a) received certain admonishments and (b) “prior to and during the making of the statement, knowingly, intelligently, and voluntarily waived the rights set out in the warning prescribed by Subsection (a) of this section.” Id.  There is no requirement, however, that an audio or video recording be made of the statement.

Mendoza provided his statement to Captain Saenz.  The statement was typed and printed; Mendoza’s initials were affixed to each of the statutorily prescribed warnings; and the statement was signed by Mendoza.  Thus, the face of Mendoza’s written statement shows compliance with Article 38.22, Section 2.  Id.  An audio or video recording of the statement was not necessary and, therefore, the trial court did not abuse its discretion in admitting the statement into evidence.

C.        Crawford and the Sixth Amendment

On appeal, Mendoza asserts both the 911 recording and the written statement were admitted in violation of Mendoza’s Sixth Amendment right to confront witnesses under the United States Constitution.  Specifically Mendoza argues:  (1) the 911 recording was played before the jury prior to identifying the caller B allegedly Mendoza B

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