Kenneth Richardson v. State

CourtCourt of Appeals of Texas
DecidedFebruary 3, 2005
Docket01-04-00281-CR
StatusPublished

This text of Kenneth Richardson v. State (Kenneth Richardson 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
Kenneth Richardson v. State, (Tex. Ct. App. 2005).

Opinion

Opinion issued February 3, 2005



In The

Court of Appeals

For The

First District of Texas


NO. 01-04-00281-CR

____________

KENNETH RICHARDSON, Appellant

V.

THE STATE OF TEXAS, Appellee


On Appeal from the 184th District Court

Harris County, Texas

Trial Court Cause No. 917575


MEMORANDUM OPINION

          Appellant, Kenneth Richardson, pleaded guilty to the offense of aggravated robbery without an agreed punishment recommendation from the State, and the trial court assessed his punishment at confinement for 60 years. In three points of error, appellant contends that the trial court erred in not impaneling a jury to determine whether he was competent to enter his guilty plea, in denying his motion for a new trial, and in not affording him an opportunity, prior to the pronouncement of his sentence, to state why his sentence should not be pronounced. We affirm.

Procedural Background

          On January 26, 2004, prior to accepting appellant’s guilty plea, the trial court asked appellant whether he had ever been mentally ill, and appellant responded that he had previously been diagnosed as “bipolar” with paranoid schizophrenia. However, in response to the trial court’s other questions, appellant replied that he understood the nature of the particular proceeding, was not taking any psychological medications at the time of his plea, was satisfied with his attorney’s work on his case, understood that he had signed a confession that he had committed the charged offense, understood that he was giving up his right to a jury trial, and had not been forced or threatened to enter a guilty plea. Appellant’s lawyer also stated that she was comfortable with appellant’s competency and his ability to understand her. The trial court accepted appellant’s guilty plea but withheld its finding of guilt. The trial court reset the case for a pre-sentence investigation (PSI) hearing.

          At the PSI hearing, held on March 24, 2004, the trial court, without objection by either party, included an addendum to a PSI report that explained that appellant had AIDS, was taking medication for the disease, and had expressed his desire that the trial court take his illness into consideration when determining his sentence. After the admission of the letter, appellant’s attorney made the following record:

In light of the particular addendum being added, we would—I would like to make a record concerning the fact that I have talked with Mr. Richardson on numerous occasions in court and over at the jail, and I feel very confident that he has understood clearly all our discussions. Every time during my conversations with him, he has been lucid, had made comments that are absolutely relevant to his case. I feel confident that I have been able to communicate with him, and he is currently in a clear thinking state and able to make decisions. May I ask him for the record if he feels that he is mentally—feeling all right now to proceed?

          The trial court then allowed appellant’s lawyer to ask appellant a series of questions regarding his mental health, to which appellant replied that he understood that he was at a PSI hearing, that he was thinking clearly and able to proceed that day, that he had been able to proceed during the course of his case, and that he had understood everything he and his attorney had discussed. In response, the trial court stated that it took “judicial notice that at the time [it] accepted the plea, [it] found him to be competent.”

Competency to Enter Plea

          In his first point of error, appellant argues that the trial court abused its discretion in not impaneling a jury to conduct a competency hearing before it sentenced appellant because “substantial evidence raised a bona fide issue as to [a]ppellant’s mental health and competence.”

          A trial court shall not accept a guilty plea unless it appears that the defendant is mentally competent and the plea is voluntary. Tex. Code Crim. Proc. Ann. art. 26.13(b) (Vernon 1989). A person is incompetent to stand trial if he does not have sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding, or a rational, as well as factual, understanding of the proceedings against him. Id. art. 46B.003(a) (Vernon Supp. 2004-2005). A person is presumed competent to stand trial and shall be found competent to stand trial unless proved incompetent by a preponderance of the evidence. Id. art. 46B.003(b) (Vernon Supp. 2004-2005). We review a trial court’s decision not to conduct a competency hearing for an abuse of discretion. See Moore v. State, 999 S.W.2d 385, 393 (Tex. Crim. App. 1999). A trial court abuses its discretion if its decision is arbitrary or unreasonable. Lewis v. State, 911 S.W.2d 1, 7 (Tex. Crim. App. 1995).

          If evidence suggesting that a defendant may be incompetent to stand trial comes to the trial court’s attention, the court, on its own motion, shall suggest that the defendant may be incompetent to stand trial. Tex. Code Crim. Proc. Ann. art. 46b.004(b) (Vernon Supp. 2004-2005). On suggestion that the defendant may be incompetent to stand trial, the court shall determine by informal inquiry whether there is some evidence from any source that would support a finding that the defendant may become incompetent to stand trial. Id. art. 46B.004(c) (Vernon Supp. 2004-2005). The trial court must conduct a competency inquiry only if the evidence raises a bona fide doubt in the trial court’s mind about the defendant’s competency to stand trial. See McDaniel v. State, 98 S.W.3d 704, 710 (Tex. Crim. App. 2003) (explaining that competency inquiry under former article 46.02 was required only if evidence brought to trial court’s attention raised bona fide doubt in trial court’s mind about defendant’s competency to stand trial).

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Kenneth Richardson v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenneth-richardson-v-state-texapp-2005.