Rafael Baez v. State

CourtCourt of Appeals of Texas
DecidedNovember 18, 2008
Docket14-07-00426-CR
StatusPublished

This text of Rafael Baez v. State (Rafael Baez 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
Rafael Baez v. State, (Tex. Ct. App. 2008).

Opinion

Affirmed and Memorandum Opinion filed November 18, 2008

Affirmed and Memorandum Opinion filed November 18, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00426-CR

RAFAEL BAEZ, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 209th District Court

Harris County, Texas

Trial Court Cause No. 1114314

M E M O R A N D U M   O P I N I O N


Appellant Rafael Baez challenges his conviction for capital murder, claiming the trial court abused its discretion in admitting appellant=s videotaped confession because the recording device, the operator, and the actual video did not meet the requirements of article 38.22, section 3(a)(3) of the Texas Code of Criminal Procedure.  Appellant also claims the trial court erred in admitting the videotape because in it, the interrogating officer continued to question appellant after he allegedly invoked his Fifth Amendment right to remain silent, signaling his intention to terminate the interview.  Because there is no merit in these points, we affirm.

I.  Factual and Procedural Background

Appellant was charged with capital murder.  At a pre-trial hearing on appellant=s motions to suppress, appellant sought to suppress his videotaped confession to police, claiming that the recording device was not capable of making an accurate recording, the video, itself, was not accurate, and the operator of the recording device was not competent.  Appellant also challenged the admissibility of the video because he claims that his words, Ado I have to say@ indicated his desire to invoke his Fifth Amendment right to remain silent and signaled his intention to terminate the interview.  The trial court denied appellant=s motions.  In the trial that followed, the trial court admitted the video into evidence, over appellant=s renewed objection, and allowed the jury to view the video in the guilt-innocence phase.  In the video, appellant confessed to shooting the complainant.

The jury found appellant guilty as charged, and the trial court sentenced him to confinement for life.

II.  Issues and Analysis

A.      Did the trial court abuse its discretion in admitting the videotape of appellant=s confession under article 38.22 of the Texas Code of Criminal Procedure?


In two issues, appellant complains that the trial court erred in admitting appellant=s videotaped confession under article 38.22, section 3(a)(3).  In his first issue, appellant claims that the recording device was incapable of an accurate recording and the operator of the device was not competent.[1]  In his second issue, appellant claims the recording, itself, was inaccurate.  Appellant filed several pre-trial motions, claiming under article 38.22, section 3(a)(3) that the recording device was not capable of making an accurate recording and the recording, itself, was not accurate.

We review a trial court=s ruling on the admissibility of evidence under an abuse-of-discretion standard.  See Guzman v. State, 955 S.W.2d 85, 89 (Tex. Crim. App. 1997).  Specifically, whether the predicate for admission of a videotaped confession has been satisfied is a matter within the trial court=s discretion.  McEntyre v. State, 717 S.W.2d 140, 146 (Tex. App.CHouston [1st Dist.] 1986, pet. ref=d).  Section 3(a)(3) of article 38.22 provides that a defendant=s oral statement is not admissible against the defendant in a criminal proceeding unless Athe recording device was capable of making an accurate recording, the operator was competent, and the recording is accurate and has not been altered.@  Tex. Code Crim. Proc. Ann. art. 38.22 (Vernon 2005 & Supp. 2008).


The trial court is within its discretion to infer that the requirements of section 3(a)(3) have been met if the tape is an accurate portrayal of the interview.  See Maldonado v. State, 998 S.W.2d 239, 246 n.9 (Tex. Crim. App. 1999); Falcetta v. State, 991 S.W.2d 295, 298 (Tex. App.CTexarkana 1999, pet. ref=d).  A person with knowledge of the interview need only testify that the video is an accurate portrayal of the interview and has not been altered in order to meet the requirements of article 38.22, section 3(a)(3).  See Minger v. State, No. 11-01-00107-CR, 2003 WL 190729, at *4 (Tex. App.CEastland 2003, no pet.) (not designated for publication) (concluding that testimony of witness with personal knowledge that the video accurately portrays the interview permits inference of compliance with article 38.22, section 3(a)(3)); see also Tex. R. Evid. 901(b)(1); Angleton v. State, 971 S.W.2d 65, 67 (Tex. Crim. App. 1998).

Appellant complains that the audio quality and an Aelectronic hum,@ as heard for most of the video, contributes to the poor quality of the video and affects the accuracy of the recording.  In this case, Officer Mosqueda had personal knowledge of the video because he conducted the interview with appellant.  See Tex. R. Evid. 901(b)(1); Minger, 2003 WL 190729, at *4; see also Falcetta, 991 S.W.2d at 298.  At times, it is difficult to hear appellant speak on the video, and the parties and the trial court acknowledged as much at the pre-trial hearing.  Officer Mosqueda testified that he asked appellant to sit up and speak more clearly several times in the interview because appellant=

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Hargrove v. State
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Guzman v. State
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McEntyre v. State
717 S.W.2d 140 (Court of Appeals of Texas, 1986)
Anderson v. State
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Watson v. State
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