Michelle Haufrect Crowden v. Department of Family and Protective Services

CourtCourt of Appeals of Texas
DecidedJanuary 29, 2009
Docket01-07-00025-CV
StatusPublished

This text of Michelle Haufrect Crowden v. Department of Family and Protective Services (Michelle Haufrect Crowden v. Department of Family and Protective Services) 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
Michelle Haufrect Crowden v. Department of Family and Protective Services, (Tex. Ct. App. 2009).

Opinion

Opinion issued January 29, 2009







In The

Court of Appeals

For The

First District of Texas

_________



NO. 01-07-00025-CV

___

__________



MICHELLE HAUFRECT CROWDEN, Appellant



V.



DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellee

__________________________________________________________________



On Appeal from the 328th District Court

Fort Bend County, Texas

Trial Court Cause No. 02-CV-127414



MEMORANDUM OPINION



The Department of Family and Protective Services tried this parental rights termination proceeding before a jury. The jury determined that Michelle Haufrect Crowden's parental rights should be terminated, and the trial court entered an order terminating Crowden's parental rights to her daughter, R.H. Crowden filed a motion for new trial, which the trial court heard and denied. This Court abated and remanded for further development of the record regarding ineffective assistance of counsel, after which the trial court found there to be no ineffective assistance of counsel. Haufrect appealed, asserting a single challenge to the effectiveness of her trial counsel.

Ineffective Assistance of Counsel

On appeal, appellant challenges only the effectiveness of trial counsel, arguing that counsel failed to (1) include ineffective assistance of counsel as a point in her statement of points for appeal, (2) seek funds for expert assistance regarding appellant's psychiatric diagnosis and medical state, (3) properly investigate the case or prepare for trial, including failing to interview and/or call witnesses (4) ask for a continuance, (5) impeach a critical witness, and (6) properly present appellant's motion for new trial by failing to have appellant present at the hearing.

Standard of Review

In parental termination cases, when there is mandatory appointment of counsel, the appointed counsel must be held accountable if she is ineffective. In re J.M.S., 43 S.W.3d 60, 63 (Tex. App.--Houston [1st Dist.] 2001, no pet.). The right-to-counsel standard in criminal cases is the same standard that is to be used in parental-termination cases. Id.

The United States Supreme Court, in Strickland v. Washington, has held that the "benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland v. Washington, 466 U.S. 668, 686, 104 S. C t. 2052, 2064 (1984). Strickland establishes two factors for determining the proper standard for attorney performance. First, the performance must be deficient to the level that counsel made errors so serious that counsel was not functioning as the "counsel" guaranteed to the defendant by the Sixth Amendment, and, second, the defendant must show that the deficient performance prejudiced the defense. Id. 466 U.S. at 687, 104 S. Ct. at 2064. The counsel's errors must have been so serious as to deprive the defendant of a fair trial, and there is a reasonable probability that, but for the counsel's unprofessional errors, the result would have been different. Id., 466 U.S. at 694, 104 S. Ct. at 2068.

There is a strong presumption that counsel's conduct fell within the wide range of reasonable professional assistance, and the defendant must overcome the presumption that the challenged action might be considered sound trial strategy. Id., 466 U.S. at 689, 104 S. Ct. at 2065. To overcome the presumption of reasonable professional assistance, "any allegation of ineffectiveness must be firmly founded in the record, and the record must affirmatively demonstrate the alleged ineffectiveness." Thompson v. State, 9 S.W.3d at 808, 814 (Tex. Crim. App. 1999). When determining the validity of an ineffective assistance of counsel claim, judicial review must be highly deferential to trial counsel and avoid the deleterious effects of hindsight. Ingham v. State, 679 S.W.2d 503, 509 (Tex. Crim. App. 1984). When the record is silent as to the reasons for counsel's conduct, a finding that counsel was ineffective would normally require impermissible speculation by the appellate court. Stults v. State, 23 S.W.3d 198, 208 (Tex. App--Houston [14th Dist.] 2000, pet. ref'd). Absent specific explanations for counsel's decisions, a record on direct appeal will rarely contain sufficient information to evaluate an ineffective assistance claim. Bone v. State, 77 S.W.3d 828, 833 (Tex. Crim. App. 2002).

However, "when no reasonable trial strategy could justify trial counsel's conduct, counsel's performance falls below an objective standard of reasonableness as a matter of law, regardless of whether the record adequately reflects trial counsel's subjective reasons for acting as [she] did." Andrews v. State, 159 S.W.3d 98, 102 (Tex. Crim. App. 2005). If a criminal defendant can prove trial counsel's performance was deficient, she must still affirmatively prove she was prejudiced by counsel's actions. Thompson, 9 S.W.3d at 812. This requires the defendant to demonstrate a reasonable probability that the result of the proceeding would have been different if trial counsel had acted professionally. Id. "A reasonable probability is a probability sufficient to undermine confidence in the outcome." Mallett v. State, 65 S.W.3d 59, 63 (Tex. Crim. App. 2001).

Failure to Include Ineffective Assistance in Statement of Points

Appellant asserts that her trial counsel was ineffective because counsel did not include an ineffective assistance of counsel point in her statement of points for appeal. However, the record shows that this is an incorrect statement.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Mallett v. State
65 S.W.3d 59 (Court of Criminal Appeals of Texas, 2001)
Bermea v. Texas Department of Family & Protective Services
265 S.W.3d 34 (Court of Appeals of Texas, 2008)
Miniel v. State
831 S.W.2d 310 (Court of Criminal Appeals of Texas, 1992)
Stults v. State
23 S.W.3d 198 (Court of Appeals of Texas, 2000)
Bone v. State
77 S.W.3d 828 (Court of Criminal Appeals of Texas, 2002)
Doe v. Brazoria County Child Protective Services
226 S.W.3d 563 (Court of Appeals of Texas, 2007)
Shull v. United Parcel Service
4 S.W.3d 46 (Court of Appeals of Texas, 1999)
Andrews v. State
159 S.W.3d 98 (Court of Criminal Appeals of Texas, 2005)
Ortiz v. State
866 S.W.2d 312 (Court of Appeals of Texas, 1993)
Ex Parte Ewing
570 S.W.2d 941 (Court of Criminal Appeals of Texas, 1978)
Ingham v. State
679 S.W.2d 503 (Court of Criminal Appeals of Texas, 1984)
In the Interest of J.T.G., H.N.M., Children
121 S.W.3d 117 (Court of Appeals of Texas, 2003)
In the Interest J.M.S.
43 S.W.3d 60 (Court of Appeals of Texas, 2001)

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Michelle Haufrect Crowden v. Department of Family and Protective Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michelle-haufrect-crowden-v-department-of-family-a-texapp-2009.