Salvador Torres Rodriguez v. State

CourtCourt of Appeals of Texas
DecidedNovember 9, 2010
Docket14-09-00625-CR
StatusPublished

This text of Salvador Torres Rodriguez v. State (Salvador Torres Rodriguez 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
Salvador Torres Rodriguez v. State, (Tex. Ct. App. 2010).

Opinion

Affirmed and Opinion filed November 9, 2010.

In The

Fourteenth Court of Appeals

NO. 14-09-00625-CR

Salvador Torres Rodriguez, Appellant

v.

The State of Texas, Appellee

On Appeal from the 149th District Court

Brazoria County, Texas

Trial Court Cause No. 56,899

OPINION

A jury convicted appellant Salvador Torres Rodriguez of murder and assessed punishment at 50 years’ imprisonment.  Appellant challenges his conviction in four issues, arguing that the trial court erred by failing to conduct a sua sponte informal inquiry into his competency, denying his motion for new trial based on incompetency, denying his request for a competency examination prior to the hearing on his motion for new trial, and denying his motion for new trial based on ineffective assistance of counsel.  We affirm.

Background

On the night of the murder, appellant was beaten up by a group of men in the trailer park where he worked as a maintenance man and groundskeeper.  Appellant then drove his truck into the crowd of men who attacked him, killing one.  Despite the defense’s argument that appellant was acting in self defense, the jury found him guilty of murder.  At sentencing, appellant’s daughter explained that appellant had epilepsy.  After appellant was sentenced, his appellate counsel filed several motions in the trial court.  First, appellate counsel asked the court to appoint an expert to evaluate appellant because appellate counsel believed appellant to be incompetent.  Appellate counsel also filed a motion for new trial, alleging that appellant had been incompetent to stand trial and that he received ineffective assistance of counsel.  According to appellant’s brief, the court held a hearing on the motion to appoint an expert, but this hearing was not transcribed and does not appear in the record.  The court subsequently denied the request to appoint an expert, held a hearing on the motion for new trial, and denied the motion for new trial.  The only witnesses to testify at the hearing were appellant’s trial counsel and appellant’s daughter.  This appeal followed.

Analysis

A.          Competency Inquiries

Appellant argues in his first issue that the trial court erred by not conducting a sua sponte informal inquiry into his competency because evidence before the court raised a bona fide doubt as to his competency.  He argues in his third issue that the trial court erred by denying his motion for new trial, which alleged he was actually incompetent at the time of trial.  The State suggests that our review should be limited to the trial court’s denial of appellant’s motion for new trial and that we need not address whether the court should have conducted an informal inquiry.  We conclude, however, that each point of error “relates to trial court conduct at different stages in the proceedings and, consequently, presents a different issue for review.”  Brown v. State, 960 S.W.2d 772, 774 (Tex. App.—Dallas 1997, pet. ref’d).  We address each issue in turn.

1.      Sua Sponte Informal Inquiry

A defendant is incompetent when he or she lacks (1) sufficient present ability to consult with counsel with a reasonable degree of rational understanding or (2) a rational and factual understanding of the legal proceedings.  Tex. Code Crim. Proc. Ann. art. 46B.003(a) (West 2006).  A trial court has an obligation to sua sponte hold an informal inquiry into competency if “evidence suggesting the defendant may be incompetent to stand trial comes to the attention of the court.”  Tex. Code Crim. Proc. Ann. art.  46B.004(b) (West 2006).  After the informal inquiry, if the court determines some evidence exists that would support a finding of incompetence, then the court must appoint an expert to examine the defendant and hold a trial to determine whether the defendant is actually incompetent to stand trial on the merits.  Tex. Code Crim. Proc. Ann. art. 46B.004–.005 (West 2006).

The “evidence” required to trigger the mandatory informal inquiry can be any fact brought to the court’s attention that raises a bona fide doubt regarding the defendant’s competency.  Fuller v. State, 253 S.W.3d 220, 228 (Tex. Crim. App. 2008); Criswell v. State, 278 S.W.3d 455, 458 (Tex. App.—Houston [14th Dist.] 2009, no pet.).  Evidence sufficient to create a bona fide doubt includes facts regarding the defendant’s “recent severe mental illness, at least moderate retardation, or truly bizarre acts by the defendant.”  Fuller, 253 S.W.3d at 228 (quotation omitted).  Evidence sufficient to create a bona fide doubt may also include any other fact from a reasonable or credible source that tends to show incompetence.  Alcott v. State, 51 S.W.3d 596, 599 (Tex. Crim. App. 2001); see also Kostura v. State, 292 S.W.3d 744, 749 (Tex. App.—Houston [14th Dist.] 2009, no pet.) (Sullivan, J., concurring).  This evidence need not be sufficient to find a defendant actually incompetent.  Fuller, 253 S.W.3d at 228.  It must simply create “‘a real doubt in the judge’s mind as to the defendant’s competency.’”  Kostura, 292 S.W.3d at 747 (majority opinion) (quoting Alcott, 51 S.W.3d at 599 n.10).  We review a trial court’s implicit decision to not hold a sua sponte informal inquiry for an abuse of discretion.  Id. at 746.

A defendant has the right to be competent throughout his or her entire trial, which includes sentencing.  Casey v. State, 924 S.W.2d 946, 949 (Tex. Crim. App. 1996).  Thus, the Texas competency statutes “allow competency to be raised, by either party or the judge, at any time before sentence is pronounced.”  Morris v. State, 301 S.W.3d 281, 290 (Tex. Crim. App. 2009).  “[S]entencing marks the final act of the trial stage [and] closes the door on the trial.”  Casey, 924 S.W.2d at 949.  Accordingly, when determining if the trial court should have had a bona fide doubt as to competency, we do not typically consider evidence brought to the trial court’s attention for the first time after sentencing.  See Purchase v. State, 84 S.W.3d 696, 699 (Tex. App.—Houston [1st Dist.] 2002, pet.

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