Ronald Edwin Duncan v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 18, 2024
Docket09-22-00367-CR
StatusPublished

This text of Ronald Edwin Duncan v. the State of Texas (Ronald Edwin Duncan v. the State of Texas) 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
Ronald Edwin Duncan v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-22-00367-CR __________________

RONALD EDWIN DUNCAN, Appellant

V.

THE STATE OF TEXAS, Appellee

__________________________________________________________________

On Appeal from the County Court at Law No. 4 Montgomery County, Texas Trial Cause No. 22-366923 __________________________________________________________________

MEMORANDUM OPINION

Ronald Edward Duncan was charged by complaint and information with the

offense of displaying a fictitious license plate. 1 The trial court entered a plea of not

guilty on Duncan’s behalf. Following a jury trial in which he appeared pro se, the

jury found Duncan guilty of the offense and assessed his punishment at 120 days in

jail.

1Tex. Transp. Code Ann. § 504.945(a)(4).

1 In this pro se appeal, Duncan raises eight issues for our review. We affirm the

trial court’s judgment.

Background

On May 6, 2022, Deputy Jose Torres of the Montgomery County Constable’s

Office, Precinct Two, observed a four-door Cadillac driving without a front license

plate. As Torres pulled behind the vehicle to initiate a traffic stop, he noticed the

vehicle was displaying a white tag that said “PRIV4T3” in the back. The tag was not

displaying the name or insignia of any state or country, as would be typical on a

license plate. When he ran the tag through his system, it did not come back to a four-

door white Cadillac. In Torres’s opinion, the tag was not a valid license plate issued

by the State of Texas or any other legitimate governmental body. During the course

of his investigation, Torres learned Duncan had purchased the license plate and

displayed it on his vehicle.

Duncan testified at trial. He admitted he did not have a front license plate and

that he purchased the back license plate online and attached it to his vehicle. Duncan

explained that the license plate was a “public notice to my fiduciary public servants”

that it was his “private property” and that he “was simply claiming [his] right to

travel in the use of private property.”

2 Standard of Review

Duncan appeared pro se at trial and on appeal. A pro se litigant must comply

with the rules of evidence and procedure and is not to be granted any special

treatment because he has asserted his pro se rights. Johnson v. State, 760 S.W.2d

277, 279 (Tex. Crim. App. 1988); Griffis v. State, 441 S.W.3d 599, 612 (Tex. App.—

San Antonio 2014, pet. ref’d). Although we construe pro se arguments “with

patience and liberality[,]” Duncan, as a pro se appellant, is not entitled to any special

treatment and is held to the same standards as licensed attorneys. Barnes v. State,

832 S.W.2d 424, 426 (Tex. App.—Houston [1st Dist.] 1992, orig. proceeding); see

also Grubbs v. State, 440 S.W.3d 130, 133 n.1 (Tex. App.—Houston [14th Dist.]

2013, pet. ref’d).

To preserve error for review, a litigant must timely object to the alleged error

and state the grounds for the ruling sought from the trial court with sufficient

specificity to make the trial court aware of the complaint, unless the specific grounds

were apparent from the context of the objection. See Tex. R. App. P. 33.1(a)(1)(A);

Dixon v. State, 2 S.W.3d 263, 265 (Tex. Crim. App. 1998). The purposes of requiring

a timely, specific objection are (1) to inform the judge of the basis of the objection

and give him the chance to make a ruling on it, and (2) to give opposing counsel the

chance to remove the objection or provide other testimony. Garza v. State, 126

3 S.W.3d 79, 82 (Tex. Crim. App. 2004) (citing Zillender v. State, 557 S.W.2d 515,

517 (Tex. Crim. App. 1977)).

An appellate brief must state all issues presented for review clearly and

concisely and include appropriate citations to authorities and to the record. See Tex.

R. App. P. 38.1(f), (i). Duncan’s brief raises sub-issues within in each main issue.

When an appellant raises multiple issues in a single point of error, the point of error

is multifarious, and an appellate court may decline to address those matters. See

Mays v. State, 318 S.W.3d 368, 390 n.82 (Tex. Crim. App. 2010) (citing Wood v.

State, 18 S.W.3d 642, 649 n.6 (Tex. Crim. App. 2000)). However, we may address

the issue in the interest of justice if we can determine, with reasonable certainty, the

alleged error about which a complaint is made. See Davidson v. State, 249 S.W.3d

709, 717 n.2 (Tex. App.—Austin 2008, pet. ref’d); Marcum v. State, 983 S.W.2d

762, 767 n.1 (Tex. App.—Houston [14th Dist.] 1998, pet. ref’d); Barnes v. State,

634 S.W.2d 25, 26 (Tex. App.—Beaumont 1982, no pet.).

Issue One

In his first issue, Duncan complains that the trial court ignored (1) Duncan’s

affidavits “Denying Corporate Existence,” “Declaring [his] Lawful Status as an

Indigenous American man,” and declaring that he was present only by “special

visitation” and not by “general appearance;” (2) Torres’s failure to provide the “‘due

process’ mandate of TCCrP 14.06;” and (3) Torres’s lack of certification to perform

4 roadside inspections and “lack of jurisdiction by the prosecution and a non-credible

witness lacking authority to enforce transportation codes.”

Before trial, Duncan filed a document titled “Affidavit of Fact Denying

Corporate Existence as ‘Mandated’ by Texas Rules of Court Rule 52,” objecting to

any document that contains a “corporate legal fiction identity” and asserting that

Duncan is “a living sentient soul, a natural born Christian American man, a free man

on the land before the ‘Common Law.’” He also filed an “Affidavit of Truth and

Fact-Counter claim #CR22-366922-23” stating that he “attend[s] this Foreign

Corporate Tribunal by ‘special presence’ and NOT by ‘general appearance[,]’”

objecting to the lack of due process under “TCCrP 14.06-15.17 & 17.30;” and

claiming the trial court lacked “proof of jurisdiction[.]”

Prior to trial, Duncan told the court that “I have – I’ve challenged – I’ve

objected to proceeding and I’ve challenged jurisdiction.” The trial court overruled

his objection. Duncan also challenged subject matter jurisdiction, claiming that the

prosecution “has not proven jurisdiction in the record.” He further stated that

“another element of jurisdiction is the due process of an examining trial” and that

“the clerk must have, in her possession, the transcripts from an examining trial and

the commitment order from the Judge that found probable cause.” The trial court

overruled Duncan’s objections.

5 “Subject matter jurisdiction is conferred on a court by statute or constitution.”

Estrada v. State, 148 S.W.3d 506, 508 (Tex. App.—El Paso 2004, no pet.) (citing

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Wood v. State
18 S.W.3d 642 (Court of Criminal Appeals of Texas, 2000)
Williams v. State
235 S.W.3d 742 (Court of Criminal Appeals of Texas, 2007)
Davidson v. State
249 S.W.3d 709 (Court of Appeals of Texas, 2008)
Dixon v. State
2 S.W.3d 263 (Court of Criminal Appeals of Texas, 1999)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Marcum v. State
983 S.W.2d 762 (Court of Appeals of Texas, 1999)
Zillender v. State
557 S.W.2d 515 (Court of Criminal Appeals of Texas, 1977)
Estrada v. State
148 S.W.3d 506 (Court of Appeals of Texas, 2004)
Salazar v. State
38 S.W.3d 141 (Court of Criminal Appeals of Texas, 2001)
Mays v. State
318 S.W.3d 368 (Court of Criminal Appeals of Texas, 2010)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Campbell v. State
358 S.W.2d 376 (Court of Criminal Appeals of Texas, 1962)
Johnson v. State
760 S.W.2d 277 (Court of Criminal Appeals of Texas, 1988)
Barnes v. State
832 S.W.2d 424 (Court of Appeals of Texas, 1992)
Fairfield v. State
610 S.W.2d 771 (Court of Criminal Appeals of Texas, 1981)
Ragston, Joshua Dewayne
424 S.W.3d 49 (Court of Criminal Appeals of Texas, 2014)
Travis Lynn Grubbs v. State
440 S.W.3d 130 (Court of Appeals of Texas, 2013)
Phillip Wayne Griffis v. State
441 S.W.3d 599 (Court of Appeals of Texas, 2014)

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