Robert Watt v. State

CourtCourt of Appeals of Texas
DecidedFebruary 11, 1999
Docket03-97-00213-CR
StatusPublished

This text of Robert Watt v. State (Robert Watt 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
Robert Watt v. State, (Tex. Ct. App. 1999).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-97-00213-CR
Robert Watt, Appellant


v.



The State of Texas, Appellee



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 299TH JUDICIAL DISTRICT

NO. 0955583, HONORABLE JON N. WISSER, JUDGE PRESIDING

A jury found appellant Robert Watt guilty of capital murder. Tex. Penal Code Ann. § 19.03(a)(2) (West 1994). The State did not seek the death penalty, and the district court assessed punishment at imprisonment for life. Tex. Penal Code Ann. § 12.31(a) (West 1994); Tex. Code Crim. Proc. Ann. art. 37.071, § 1 (West Supp. 1998). We will affirm.

David Reynolds, Jason Ishee, and Watt, each of whom was eighteen or nineteen years old, spent the late afternoon of October 31, 1995, loitering outside an Austin shopping mall. As night fell, Watt and Ishee agreed on a scheme to steal Reynolds's ten-year-old car. They asked Reynolds to drive them to an apartment complex, ostensibly to purchase marihuana. At the complex, they lured Reynolds to the rear of the building where they beat him to death with their fists and feet, and with a large rock. Watt and Ishee took Reynolds's car and five dollars they found in his pocket, then drove to Ishee's girlfriend's house. Ishee showed the girl the blood on his hands and bragged that he had killed someone. Watt and Ishee spent the rest of that night and the following day driving around Austin in Reynolds's car, then left town. They were arrested on November 3 in Wharton, still driving the stolen vehicle. Each man gave a written statement to the police admitting the robbery-murder, blaming the other as the chief actor, and denying an intent to kill Reynolds. (1)

In his first point of error, Watt contends the district court erred by "failing to grant a mistrial in order to sever appellant's cause." Prior to trial, Watt moved to sever his prosecution from that of his codefendant Ishee. The motion was premised on the assumption that the statement he gave to the police would be edited to remove references to Ishee before being admitted in evidence, thus avoiding Bruton error. See Bruton v. United States, 391 U.S. 123, 135-36 (1968) (defendant's confrontation right violated by admission at joint trial of nontestifying codefendant's confession that incriminates both defendants); Richardson v. Marsh, 481 U.S. 200, 211 (1987) (Bruton error avoided by redacting codefendant's confession to remove references to defendant). It was Watt's contention that he would be unable to offer the redacted portions of his statement asserting Ishee's greater culpability, and thus would be denied the opportunity to assert his allegedly lesser culpability. See Finley v. State, 917 S.W.2d 122, 125-26 (Tex. App.--Austin 1996, pet. ref'd) (if rule of optional completeness conflicts with codefendant's confrontation right, constitutional right must prevail over evidentiary rule). The severance motion was withdrawn at a pretrial hearing after the prosecutor stated, "We're not planning to redact any portion of anyone's statement; not a sentence, not a period, either one of their statements."

During trial, the State offered in evidence each defendant's complete, unedited written statement to the police. Watt objected to the admission of Ishee's statement on Bruton grounds; Ishee objected to Watt's statement on the same grounds. The court responded by ordering both statements edited to remove references to the codefendant. Watt then renewed his motion to sever and requested a mistrial as to himself, so that he might be tried separately. The motions were overruled. Watt contends the court's rulings denied him due process by preventing him from offering mitigating and exculpatory evidence to the jury, by which we assume he means those redacted portions of his written statement in which he described Ishee's role in the murder.

Watt's brief on appeal contains no argument or citation to authority in support of his assertion that his due process rights were violated. The attempt to renew the motion to sever in the middle of trial was untimely. See Foster v. State, 652 S.W.2d 474, 477 (Tex. App.--Houston [1st Dist.] 1983), aff'd, 693 S.W.2d 412 (Tex. Crim. App. 1985). And rather than denying the defendants due process, the redaction of the statements was necessary to insure their due process rights. See Pointer v. Texas, 380 U.S. 400, 403 (1965) (Fourteenth Amendment incorporates confrontation right). The district court was required to redact all references to Watt from Ishee's statement after Watt asserted his constitutional confrontation right. Similarly, the court was required to redact all references to Ishee from Watt's statement after Ishee asserted his confrontation right. No error is presented. Point of error one is overruled.

Watt next asserts that his trial counsel's handling of the severance issue denied him effective assistance. To prevail on a claim of ineffective assistance of counsel at the guilt stage, an appellant must show that counsel made such serious errors that he was not functioning effectively as counsel and that these errors prejudiced the appellant's defense to such a degree that he was deprived of a fair trial. Strickland v. Washington, 466 U.S. 668 (1984); Hernandez v. State, 726 S.W.2d 53, 57 (Tex. Crim. App. 1986); and see Moore v. State, 694 S.W.2d 528, 531 (Tex. Crim. App. 1985); O'Hara v. State, 837 S.W.2d 139, 143 (Tex. App.--Austin 1992, pet. ref'd). Counsel's performance must be judged in its totality, rather than by isolating individual errors or omissions. Oestrick v. State, 939 S.W.2d 232, 237 (Tex. App.--Austin 1997, pet. ref'd). We must avoid the distortions of hindsight, and evaluate counsel's conduct from his perspective at the time of trial. Ex parte Kunkle, 852 S.W.2d 499, 505 (Tex. Crim. App. 1993). A defendant asserting an ineffective assistance claim must overcome a strong presumption that counsel's conduct fell within the wide range of reasonable professional assistance. Jackson v. State, 877 S.W.2d 768, 771 (Tex. Crim. App. 1994).

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Related

Pointer v. Texas
380 U.S. 400 (Supreme Court, 1965)
Bruton v. United States
391 U.S. 123 (Supreme Court, 1968)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Richardson v. Marsh
481 U.S. 200 (Supreme Court, 1987)
Harmelin v. Michigan
501 U.S. 957 (Supreme Court, 1991)
Bullard v. State
548 S.W.2d 13 (Court of Criminal Appeals of Texas, 1977)
Ex Parte Kunkle
852 S.W.2d 499 (Court of Criminal Appeals of Texas, 1993)
Hernandez v. State
726 S.W.2d 53 (Court of Criminal Appeals of Texas, 1986)
Moore v. State
694 S.W.2d 528 (Court of Criminal Appeals of Texas, 1985)
Ex Parte Granviel
561 S.W.2d 503 (Court of Criminal Appeals of Texas, 1978)
Finley v. State
917 S.W.2d 122 (Court of Appeals of Texas, 1996)
Cameron v. State
925 S.W.2d 246 (Court of Appeals of Texas, 1995)
Foster v. State
652 S.W.2d 474 (Court of Appeals of Texas, 1983)
Foster v. State
693 S.W.2d 412 (Court of Criminal Appeals of Texas, 1985)
O'Hara v. State
837 S.W.2d 139 (Court of Appeals of Texas, 1992)
Prater v. State
903 S.W.2d 57 (Court of Appeals of Texas, 1995)
Jackson v. State
877 S.W.2d 768 (Court of Criminal Appeals of Texas, 1994)
Oestrick v. State
939 S.W.2d 232 (Court of Appeals of Texas, 1997)
Cantu v. State
939 S.W.2d 627 (Court of Criminal Appeals of Texas, 1997)
Allen v. State
552 S.W.2d 843 (Court of Criminal Appeals of Texas, 1977)

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Robert Watt v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-watt-v-state-texapp-1999.