Larry Ralph Elliott v. State

CourtCourt of Appeals of Texas
DecidedApril 14, 2005
Docket03-03-00191-CR
StatusPublished

This text of Larry Ralph Elliott v. State (Larry Ralph Elliott 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
Larry Ralph Elliott v. State, (Tex. Ct. App. 2005).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-03-00191-CR

NO. 03-03-00192-CR

Larry Ralph Elliott, Appellant



v.



The State of Texas, Appellee



FROM THE DISTRICT COURT OF WILLIAMSON COUNTY, 277TH JUDICIAL DISTRICT

NO. 02-256-K277 & 02-257-K277, HONORABLE KEN ANDERSON, JUDGE PRESIDING

M E M O R A N D U M O P I N I O N



On January 15, 2002, appellant Larry Ralph Elliot drove his truck into a grocery store, killing one woman and seriously injuring another. He was indicted for murder and aggravated assault. See Tex. Pen. Code Ann. §§ 19.02 (West 2003), 22.02 (West Supp. 2004-05). On February 13, 2002, a jury found appellant incompetent to stand trial but likely to regain competence with treatment. On January 13, 2003, another jury was empaneled to re-examine appellant's competency and, after a hearing, found appellant competent to stand trial. On February 3, trial began before a third jury, and appellant pleaded not guilty by reason of insanity. The jury found appellant guilty of both counts, sentencing him to life imprisonment for the murder and twenty years' confinement for the assault. On appeal, appellant contends that the evidence is legally and factually insufficient to support the finding that he was competent to stand trial and that the evidence is factually insufficient to support the rejection of his insanity defense. We affirm the judgments of conviction.



Competency to Stand Trial

In his first and second issues on appeal, appellant contends that the evidence is legally and factually insufficient to support the jury's finding that he was competent to stand trial.



Standard of Review

A person is incompetent to stand trial if he either lacks a sufficient present ability to consult with his attorney with a reasonable degree of rational understanding or lacks a rational and factual understanding of the proceedings against him. (1) Tex. Code Crim. Proc. Ann. art. 46B.003(a) (West Supp. 2004-05). A defendant is presumed to be competent unless proved otherwise by a preponderance of the evidence. Id., art. 46B.003(b). However, once a defendant has been adjudicated incompetent, the burden shifts to the State to prove beyond a reasonable doubt that the defendant has regained competence to stand trial. Arnold v. State, 873 S.W.2d 27, 30 (Tex. Crim. App. 1993); Manning v. State, 730 S.W.2d 744, 748 (Tex. Crim. App. 1987).

When the State bears the burden in a competency hearing, we review the factual sufficiency of the evidence supporting a finding of competence by asking whether, considering all the evidence in a neutral light, the jury was rationally justified in finding competence beyond a reasonable doubt. See Zuniga v. State, 144 S.W.3d 477, 484 (Tex. Crim. App. 2004) (discussing and clarifying standard of review applied to beyond-a-reasonable-doubt burdens of proof). The evidence may be insufficient if evidence of competence is too weak to support a finding of competence when viewed alone or if evidence of incompetence is so strong that the beyond-a-reasonable-doubt standard could not have been met. Id. at 484-85. Evidence may "preponderate" in favor of competence but still be outweighed by contrary proof and thus be factually insufficient under the beyond-a-reasonable-doubt standard. Id. at 485.



Factual Summary

The parties agree that appellant suffers from paranoid schizophrenia, dating back at least to 1988 or 1989. Dr. Michael Jumes was Chief Psychologist of the North Texas State Hospital's (2) Competency Restoration Program when appellant was admitted to the hospital after being found incompetent in February 2002. Jumes testified that while at the hospital, appellant received treatment that included medication, formal training to help him understand court procedures, stress management, and classes to help him understand his medical condition and medications. Jumes testified that appellant made substantial progress and, as of April 24, 2002, was legally competent and displayed an understanding of the difference between felony and misdemeanor charges, the possible ranges of punishment, the consequences of being found guilty, and basic legal concepts like use of evidence, plea bargains, and the roles of juries, judges, and attorneys. Appellant was discharged on May 17, 2002. Jumes testified that a person can slip in and out of competence, which is why Jumes recommended that appellant receive continuing psychiatric services.

Dr. Mary Anderson was appointed by the trial court to evaluate appellant's competency. She saw appellant five times, first in late January 2002 and, most recently, shortly before the January 2003 competency hearing. Anderson testified that in January 2002 appellant was having severe symptoms such as a high degree of paranoia, which led him to refuse to eat because he believed his food was poisoned, and intense auditory hallucinations on which he was very focused. Although appellant factually knew what the situation was and who the various people were in the courtroom, he could not interact in a reasonably coherent way due to his distracting auditory hallucinations. Anderson testified that appellant's symptoms had since lessened and, although appellant still reported hearing voices, he understood that "the voices were coming from his head," and Anderson believed he was competent to stand trial in January 2003.

The State also called Annette Hawkins, who oversees the medical department of the Williamson County Sheriff's Department. Hawkins testified that appellant's records show that while in jail after his hospital discharge in May 2002 he had received and taken his medications as prescribed. (3) Finally, the State introduced a letter written on May 2, 2002, by Dr. Thomas Wiman, Competency Program Psychiatrist for the North Texas State Hospital, stating that it was his opinion that appellant was competent to stand trial.

Discussion

Appellant asserts that no rational jury could have found beyond a reasonable doubt that he was competent to stand trial, arguing that, except for Dr. Anderson, the doctors had not examined him recently enough to prove that he was currently competent. We disagree. Although Jumes and Wiman formed their opinions in late April and early May 2002, their opinions were relevant in determining whether appellant had responded to competency treatment. Anderson testified that she saw appellant for about an hour the week before the competency trial in January 2003. Based on that and her other examinations of appellant, Anderson opined that appellant was competent. Jumes believed appellant could maintain competency with medication and psychiatric care, and there was evidence that appellant had continued to take his prescribed medication.

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Related

Sanders v. State
771 S.W.2d 645 (Court of Appeals of Texas, 1989)
Taylor v. State
856 S.W.2d 459 (Court of Appeals of Texas, 1993)
Aschbacher v. State
61 S.W.3d 532 (Court of Appeals of Texas, 2001)
Manning v. State
730 S.W.2d 744 (Court of Criminal Appeals of Texas, 1987)
Bigby v. State
892 S.W.2d 864 (Court of Criminal Appeals of Texas, 1994)
Graham v. State
566 S.W.2d 941 (Court of Criminal Appeals of Texas, 1978)
Zuniga v. State
144 S.W.3d 477 (Court of Criminal Appeals of Texas, 2004)
Taylor v. State
885 S.W.2d 154 (Court of Criminal Appeals of Texas, 1994)
Arnold v. State
873 S.W.2d 27 (Court of Criminal Appeals of Texas, 1993)

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Larry Ralph Elliott v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/larry-ralph-elliott-v-state-texapp-2005.