Nakia Brown v. Office of the Attorney General, Crime Victim Services Division

CourtCourt of Appeals of Texas
DecidedJuly 8, 2010
Docket01-10-00008-CV
StatusPublished

This text of Nakia Brown v. Office of the Attorney General, Crime Victim Services Division (Nakia Brown v. Office of the Attorney General, Crime Victim Services Division) 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
Nakia Brown v. Office of the Attorney General, Crime Victim Services Division, (Tex. Ct. App. 2010).

Opinion

Opinion issued July 8, 2010

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-10-00008-CV

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Nakia Brown, Appellant

V.

Office of the Attorney General, Crime Victim Services Division, Appellee

On Appeal from the 334th District Court

Harris County, Texas

Trial Court Case No. 0872790

MEMORANDUM OPINION

          Appellant, Nakia Brown, filed suit in the trial court seeking judicial review of the attorney general’s denial of her claim for compensation under the Crime Victims’ Compensation Act (the CVCA).  Appellee, the Office of the Attorney General, Crime Victim Services Division (attorney general), filed a motion for summary judgment, which the trial court granted.  In seven issues, Brown argues that the trial court erred in granting the attorney general’s motion for summary judgment because (1) the attorney general failed to offer proof that, as a matter of law, appellant was not a crime victim pursuant to the Act; (2) the attorney general failed to offer proof that, as a matter of law, appellant was not a victim of criminally injurious conduct pursuant to the Act; (3) it is not a requirement of the Act that the third party be charged, indicted, or convicted of any crime; (4) the trial court considered the attorney general’s affidavit of Frederick A. Edwards, a prosecutor associated with the case, as summary judgment evidence; (5) the attorney general failed to offer proof that, as a matter of law, Brown bore a share of the responsibility for the act or omission giving rise to the claim; and (6) the attorney general failed to offer proof that, as a matter of law, Brown was engaging in an activity that at the time of the criminally injurious conduct was prohibited by law or a rule made under law.  Additionally, in her eighth issue, Brown requests that, in the event that this Court remands the cause for a trial on the merits, we hold that the proportionate responsibility section of the Texas Civil Practice and Remedies Code chapter 33 does not apply to the “affirmative defenses” under the Act and the trial court should use a pure comparative fault standard.

          We affirm.

Background

On February 15, 2008, Brown, a student at Prairie View A&M University, was returning to her apartment from her on-campus job when she noticed a car parked near the apartment where Mark Williams sometimes stayed.  Brown, who was involved in a dating relationship with Williams, suspected that the car belonged to Tristen Nottage, who was also involved in a dating relationship with Williams.  Brown knocked on the door of the apartment and eventually on Williams’s bedroom door.  Williams denied that the car belonged to Nottage and told Brown to leave.  Brown then attempted to contact Nottage on her cell phone to determine if the car belonged to Nottage.  After Brown placed the phone call to Nottage, Williams came out from the apartment and again told Brown to leave.

Brown went to her own apartment in the same complex to retrieve the gifts Williams had given her for Valentine’s Day and then returned to place them on Nottage’s car.  In the intervening time, Williams and Nottage had both emerged from the apartment where Williams sometimes stayed, and Nottage got into her car to leave.  Before Nottage was able to leave the parking lot, Brown initiated a physical altercation by hitting or punching Nottage.  Nottage returned the blows, and the fight was broken up by witnesses.  Nottage then returned to her car, and Brown remained in the apartment parking lot.  As Nottage exited the parking lot, she struck Brown and another witness with her car.[1]

Brown was hospitalized as a result of her injuries and claims that she incurred medical expenses in excess of $100,000.  Brown also reported the incident to police, who arrested Nottage in Houston and charged her with aggravated assault with a deadly weapon.[2]  However, after considering Nottage’s case, a Waller County grand jury no-billed the charges against her.  As a result, Nottage was never tried or convicted of any crime related to the February 15 incident.

Brown filed an application for compensation under the CVCA seeking reimbursement for medical and other expenses.  The attorney general denied her claim, and she appealed the decision for review by the attorney general.  The attorney general’s final decision found that Brown’s “application for compensation was denied by the reviewer based upon a finding that the victim’s behavior contributed to the incident.”  It also found that

the appeal reviewer denied the claim based on the conclusion that according to the available information, no criminal charges were filed.  Specifically, [Brown] acted in a manner that directly caused the personal injury giving rise to the CVC claim [and] the credible evidence provided to CVC indicates that [Brown] acted in a manner that directly caused the personal injury giving rise to the CVC claim.  Specifically, the evidence indicates that [Brown] was the primary aggressor and that Ms. Brown was attempting to keep the alleged suspect from leaving when she was injured.

The final decision concluded, “Based on the available evidence, the attorney general is not satisfied by a preponderance of the evidence that the requirements of Chapter 56 of the Texas Code of Criminal Procedure has been met.  Therefore, the application for compensation is denied.”  Brown subsequently filed suit in the trial court seeking de novo review of her CVCA claim.

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Bluebook (online)
Nakia Brown v. Office of the Attorney General, Crime Victim Services Division, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nakia-brown-v-office-of-the-attorney-general-crime-texapp-2010.