Martin, Robert Louis v. State

CourtCourt of Appeals of Texas
DecidedOctober 27, 2005
Docket14-04-00689-CV
StatusPublished

This text of Martin, Robert Louis v. State (Martin, Robert Louis 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
Martin, Robert Louis v. State, (Tex. Ct. App. 2005).

Opinion

Affirmed and Memorandum Opinion filed October 27, 2005

Affirmed and Memorandum Opinion filed October 27, 2005.

In The

Fourteenth Court of Appeals

_______________

NO. 14-04-00689-CV

ROBERT LOUIS MARTIN, Appellant

V.

THE STATE OF TEXAS, Appellee

________________________________________________________________

On Appeal from the 232nd District Court

Harris County, Texas

Trial Court Cause No. 877,816

________________________________________________________________

M E M O R A N D U M   O P I N I O N

Appellant, Robert Louis Martin, appeals from a recommitment order extending inpatient mental health services for a period of one year.  In two issues, appellant challenges the legal and factual sufficiency of the evidence to support the order.  Because all dispositive issues are clearly settled in law, we issue this memorandum opinion and affirm.  See Tex. R. App. P. 47.4


I.  Background

In May 2001, appellant stabbed a cab driver with a knife several times in the chest and back causing serious, but nonfatal, injuries.  Appellant was arrested and charged with aggravated assault.  Following a bench trial, the trial court found appellant not guilty by reason of insanity, and ordered that he be committed to the maximum security unit at the North Texas State Hospital.  Subsequently, the commitment order was extended four times. The most recent extension, in June of 2004, forms the basis of this appeal.

II.  Statutory Requirements for Commitment

Commitment proceedings concerning persons who have been found not guilty by reason of insanity are civil in nature.  Campbell v. State, 85 S.W.3d 176, 180 (Tex. 2002).  A court may renew an order for inpatient mental health services if it finds the patient meets the criteria for involuntary commitment set forth in section 574.035(a) of the Texas Health and Safety Code.  See Tex. Health & Safety Code Ann. ' 574.066(f) (Vernon 2003) (specifying the procedure for the renewal of an order for extended mental health services).

Pursuant to Section 574.035(a), the court may order extended inpatient mental health services if the trier of fact finds, by clear and convincing evidence, that among other requirements, the proposed patient meets the following criteria:

(1) the proposed patient is mentally ill; and

(2) as a result of that mental illness the proposed patient:

(A) is likely to cause serious harm to himself;

(B) is likely to cause serious harm to others; or

(C) is:

(i) suffering severe and abnormal mental, emotional, or physical distress;


(ii) experiencing substantial mental or physical deterioration of the proposed patient=s ability to function independently, which is exhibited by the proposed patient=s inability, except for reasons of indigence, to provide for the proposed patient=s basic needs, including food, clothing, health, or safety; and

(iii) unable to make a rational and informed decision as to whether or not to submit to treatment

Tex. Health & Safety Code Ann.  ' 574.035(a) (Vernon 2003).[1]

            Clear and convincing evidence is Athat measure or degree of proof which will produce in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established.@  State v. Addington, 588 S.W.2d 569, 570 (Tex. 1979).  In order to be clear and convincing under section 574.035(a), the evidence must also include expert testimony and, unless waived, evidence of a recent overt act or a continuing pattern of behavior that tends to confirm (1) the likelihood of serious harm to the proposed patient or others, or (2) the proposed patient=s distress and the deterioration of the proposed patient=s ability to function.  Tex. Health & Safety Code Ann. ' 574.035(e) (Vernon 2003).

III.  Sufficiency of the Evidence

The judge or jury must specify which criterion under the Texas Health and Safety Code forms the basis for the recommitment order.  Tex. Health & Safety Code Ann. ' 574.035(c) (Vernon 2003).  In this case, the jury found that appellant met two criteria for recommitment: (1) he was likely to cause serious harm to others; and (2) he was suffering severe and abnormal distress, experiencing substantial deterioration of his ability to function independently, and was unable to make a rational decision concerning treatment. 


Appellant contests the legal and factual sufficiency of the evidence to support both findings. 

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Addington
588 S.W.2d 569 (Texas Supreme Court, 1979)
Campbell v. State
85 S.W.3d 176 (Texas Supreme Court, 2002)
Moss v. State
539 S.W.2d 936 (Court of Appeals of Texas, 1976)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Campbell v. State
68 S.W.3d 747 (Court of Appeals of Texas, 2001)
Broussard v. State
827 S.W.2d 619 (Court of Appeals of Texas, 1992)
Roland v. State
989 S.W.2d 797 (Court of Appeals of Texas, 1999)
In the interest of C.H.
89 S.W.3d 17 (Texas Supreme Court, 2002)
In the Interest of R.M.
90 S.W.3d 909 (Court of Appeals of Texas, 2002)
In the Interest of J.F.C.
96 S.W.3d 256 (Texas Supreme Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
Martin, Robert Louis v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-robert-louis-v-state-texapp-2005.