Rudolph Foley v. State

CourtCourt of Appeals of Texas
DecidedMay 3, 2012
Docket01-11-00113-CR
StatusPublished

This text of Rudolph Foley v. State (Rudolph Foley 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
Rudolph Foley v. State, (Tex. Ct. App. 2012).

Opinion

Opinion issued May 3, 2012

In The

Court of Appeals

For The

First District of Texas

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NOS. 01-11-00113-CR & 01-11-00114-CR

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Rudolph Foley, Appellant

V.

The State of Texas, Appellee

On Appeal from the 178th District Court

Harris County, Texas

Trial Court Case Nos. 1205088 & 1205089

MEMORANDUM OPINION

Appellant Rudolph Foley was convicted in a jury trial of delivery of heroin, weighing more than 1 gram and less than 4 grams,[1] and possession of cocaine with intent to deliver, weighing more than 4 grams and less than 200 grams.[2]  Both charges were enhanced with two previous felony convictions for drug possession.  The court sentenced him to thirty years’ confinement. 

On appeal, appellant challenges (1) the admission of testimony about the test performed on the drugs seized because the chain-of-custody evidence was allegedly deficient, and (2) the sufficiency of the evidence establishing the weight of the drugs.  We affirm.

BACKGROUND

Undercover Officer Sinegal with the Houston Police Department testified that he called appellant and arranged to go to appellant’s trailer to purchase 15 baggies of heroin from him.  When Sinegal arrived, appellant was sitting at an outside table near a barbeque pit.  After Sinegal gave appellant the agreed-upon $150, Sinegal watched as appellant retrieved the baggies of heroin from the barbeque pit.  Sinegal saw a bag of crack cocaine sitting next to the heroin in the barbeque pit. 

After the transaction was complete, Sinegal returned to his car and called in marked patrol units to arrest appellant.  He also called his partner, Officer Patel, to describe the location of the crack cocaine in the barbeque pit.  Appellant was arrested within minutes of the heroin transaction, and Patel testified that he located crack cocaine in the barbeque pit exactly as described by Sinegal.  After the arrest, Sinegal drove back to appellant’s trailer to confirm for the uniformed officers that the correct person had been taken into custody.  Patel gave the seized cocaine to Sinegal, as well as the money recovered (to confirm that its serial numbers matched the money Sinegal used in the buy). 

Both officers testified to later meeting back at their office to process the case.   Sinegal gave the narcotics to Patel to weigh and test while Patel drafted the charges.  Sinegal was present and watched Patel weigh, test, and place the crack cocaine and fifteen baggies of heroin into two separate clear bags, and then put those two bags into a manila evidence envelope.  Sinegal then marked and sealed that manila envelope in Patel’s presence.  Patel placed the envelope in the department’s narcotics lockbox.  The only people who have access to the drugs in the lockbox are people in the crime laboratory.    

On the day of trial, Sinegal went to the crime laboratory and retrieved the envelope containing the narcotics seized from appellant.  During trial, he identified the envelope by his initials written on the outside of the envelope, along with the date, appellant’s name, and the offenses for which appellant was charged.  That manila envelope was marked as State’s Exhibit Number 6.  After Sinegal identified State’s Exhibit 6, the State opened the envelope, removed the contents, and marked the clear bag holding the fifteen baggies of heroin as State’s Exhibit Number 7, and the clear bag containing the crack cocaine as State’s Exhibit Number 8.  Sinegal testified that he recognized State’s Exhibit Numbers 7 and 8 as the narcotics he seized from appellant because he watched Patel put them into Exhibit 6 before he himself marked and sealed that manila envelope.  Patel similarly testified that he recognized State’s Exhibit 7 and 8 as the narcotics that he weighed, tested, and placed in State’s Exhibit Number 6.

Criminalist Kerry Adams testified that she recognized State’s Exhibits Number 7 and 8 as the narcotics that she tested in this case, and State’s Exhibit Number 6 as the envelope that contained them.  Her in-court identification of these exhibits was based on the laboratory number assigned to this case and her initials that she wrote on each of the exhibits.  Although State’s Exhibits 7 and 8 were not marked by Sinegal or Patel, Adams testified that she knew that they came from State Exhibit 6 because she wrote the laboratory number and the incident number on all three exhibits when she opened State’s Exhibit Number 6 and inventoried its contents. 

Ultimately, State’s Exhibit Numbers 7 and 8 (the bags containing the seized controlled substances) were admitted into evidence, but Exhibit Number 6 (the manila envelope that Exhibits 7 and 8 were placed in) was not admitted.

Adams testified that the contents of Exhibits 7 and 8 had not been tampered with since coming into the laboratory’s possession, outside of what was necessary to perform testing.  A previous criminologist had done testing before Adams, but Adams testified that the prior work was properly documented.  Adams retested the evidence because the original criminalist was on maternity leave. 

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Rudolph Foley v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rudolph-foley-v-state-texapp-2012.