Rhea v. State

705 S.W.2d 165, 1985 Tex. App. LEXIS 12400
CourtCourt of Appeals of Texas
DecidedNovember 19, 1985
Docket6-84-112-CR
StatusPublished
Cited by12 cases

This text of 705 S.W.2d 165 (Rhea 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
Rhea v. State, 705 S.W.2d 165, 1985 Tex. App. LEXIS 12400 (Tex. Ct. App. 1985).

Opinions

BLEIL, Justice.

Howard Rhea appeals his conviction of the aggravated sexual assault of his two-year-old daughter. He complains that the child’s videotaped statement should not have been admitted in evidence, raising the pivotal issue of whether the child was a competent witness. Because we conclude that the child was not a competent witness, admission of her videotaped statement violated Tex.Code Crim.Proc.Ann. art. 38.071 (Vernon Supp.1985). Therefore, we reverse the judgment.

In February 1984, Rhea and his wife separated and in March Shirley Rhea filed for divorce. On April 2, Shirley Rhea asked the Texas Department of Human Resources to investigate her husband for sexual abuse of their child which reportedly occurred March 11. As a part of an interview with the child and Shirley Rhea, Sann Cisco, a child protective specialist for the Department of Human Resources, caused to be prepared a videotaped interview of the child. Responding to specific questioning, usually with head nods, the child indicated that an incident of sexual abuse had occurred. When the child testified under oath at the trial, she said that she remembered nothing about the interview with Cisco and that Rhea did nothing which would be sexual abuse. The jury determined that on March 11, 1984, Howard Rhea committed aggravated sexual assault upon a child and assessed punishment at forty years confinement.

At trial, Sann Cisco testified to having prepared the videotaped interview. When the State offered the videotape into evidence as State’s Exhibit 1, Rhea’s attorney objected to its admission on the grounds that the child was an incompetent witness because she did not possess sufficient intellect to relate the transactions with respect to which she was interrogated and did not understand the obligation of the oath. Another ground for his objection was that the statements on the videotape resulted from questions calculated to lead to a particular statement. The court overruled the objection. After the court overruled Rhea’s objection to the videotape’s admissibility and ruled that the child was competent, Rhea’s attorney called the child to testify in accordance with Tex.Code Crim.Proc.Ann. art. 38.071, § 2(a)(8) (Vernon Supp.1985). Essentially, the child indicated that she did not recall the videotaped interview. She recalled little other than having taken a bath with her daddy.

The statutory basis for admitting videotaped interviews is found in Tex.Code Crim. Proc.Ann. art. 38.071, § 2 (Vernon Supp. 1985). It provides that,

(а) The recording of an oral statement of the child made before the proceeding begins is admissible into evidence if:
(1) no attorney for either party was present when the statement was made;
(2) the recording is both visual and aural and is recorded on film or videotape or by other electronic means;
(3) the recording equipment was capable of making an accurate recording, the operator of the equipment was competent, and the recording is accurate and has not been altered;
(4) the statement was not made in response to questioning calculated to lead the child to make a particular statement;
(5) every voice on the recording is identified;
(б) the person conducting the interview of the child in the recording is present at the proceeding and available to testify or be cross-examined by either party;
(7) the defendant or the attorney for the defendant is afforded an opportunity to view the recording before it is offered into evidence; and
(8) the child is available to testify.
[167]*167(b) If the electronic recording of the oral statement of a child is admitted into evidence under this section, either party may call the child to testify, and the opposing party may cross-examine the child.1

Rhea maintains that because the child was not a competent witness, the requirement in Article 38.071, § 2(a)(8), that the child be available to testify, is not fulfilled. Ordinarily, whether a witness is competent rests within the sound discretion of the trial court. Garcia v. State, 573 S.W.2d 12 (Tex.Crim.App.1978); Fields v. State, 500 S.W.2d 500 (Tex.Crim.App.1973). The rule for determining the competency of a witness is found in Tex.Code Crim.Proc. Ann. art. 38.06 (Vernon 1979). It provides, in pertinent part, that all persons are competent to testify in criminal cases except:

Children or other persons who, after being examined by the court, appear not to possess sufficient intellect to relate transactions with respect to which they are interrogated, or who do not understand the obligation of the oath.

When Article 38.06 was first enacted in 1925, it merely codified existing case law. Child witnesses have long been required both, (1) to be able to give a clear recital of the events in question; and (2) to be aware that some sanction will attach to false swearing. Nicholas v. State, 99 Tex.Cr.R. 504, 270 S.W. 555 (1925); Valdez v. State, 71 Tex.Cr.R. 487, 160 S.W. 341 (1913); see also 1 R. Ray, Texas Law of Evidence Civil and Criminal § 294 (Texas Practice 3d ed. 1980). The trial court, without articulating any specific findings, apparently determined that the child possessed sufficient intellect and understood the obligation of an oath because the child was found to be a competent witness. The trial court based its determinations upon the child’s responses to lengthy questioning by the court, which included the use of an E.T. doll and a teddy bear. The trial court questioned her extensively concerning what was correct and what was not, her capacity to recognize what was true, and her ability to understand and accurately relate present occurrences in court concerning the E.T. doll and teddy bear. In no manner did the child indicate an ability to relate past events. Most of the child’s responses were “uh-huh”, “huh-uh” or head nods. She demonstrated an ability to accurately relate facts pertaining to the doll and teddy bear and refused to accept incorrect answers concerning the doll and teddy bear. Typical of the child’s responses which led the court to determine her to be a competent witness, is the following (references to the child’s name are deleted):

Q. [W]hat is this? Who is this? Does this have a name? You are shaking your head no. Can you say no? What is this? Is this a chipmunk or is it a bear? What is it?
A. I don’t know what its name is.
Q. You haven’t given it a name? Is it yours?
A. Uh-huh.
Q. You are shaking your head yes; is that right? And what name do you think you are going to give it? Is it a boy or girl?
A. It’s a girl.
Q. What are you going to call it?
A. Huh?
Q. How old are you? Three? Is that right? Good. Did you have a birthday party?
A. Huh-uh.
Q. No birthday party?
A. Huh-uh.

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Rhea v. State
705 S.W.2d 165 (Court of Appeals of Texas, 1985)

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705 S.W.2d 165, 1985 Tex. App. LEXIS 12400, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rhea-v-state-texapp-1985.