Samantha Nicole Wohlford v. State

CourtCourt of Appeals of Texas
DecidedSeptember 24, 2019
Docket06-19-00083-CR
StatusPublished

This text of Samantha Nicole Wohlford v. State (Samantha Nicole Wohlford 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
Samantha Nicole Wohlford v. State, (Tex. Ct. App. 2019).

Opinion

In The Court of Appeals Sixth Appellate District of Texas at Texarkana

No. 06-19-00083-CR

SAMANTHA NICOLE WOHLFORD, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 276th District Court Titus County, Texas Trial Court No. CR19088

Before Morriss, C.J., Burgess and Stevens, JJ. Memorandum Opinion by Justice Burgess MEMORANDUM OPINION Ernest Lee Ibarra, Jr., was beaten, abducted from his home, and murdered by three men

during the early morning hours of February 20, 2015. Investigation of the incident resulted in

charges of aggravated kidnapping 1 against Ibarra’s wife, Samantha Nicole Wohlford, who was

convicted by a Titus County jury and sentenced to fifty years’ imprisonment. On appeal, Wohlford

complains that the trial court erred in failing to instruct the jury that Jonathan Sanford, one of the

three men involved in Ibarra’s kidnapping and murder, 2 was an accomplice witness as a matter of

law and in failing to include a jailhouse-witness instruction in its jury charge. Because we find

that (1) the trial court did not err by not including a jailhouse-witness instruction and (2) the trial

court’s error in failing to give a proper accomplice-witness instruction was harmless, we affirm

the trial court’s judgment.

I. No Jailhouse-Witness Instruction Was Required

In her second issue, Wohlford asserts that the trial court erred in failing to give a jailhouse-

witness instruction. Wohlford argues that Whitney Smith, who was incarcerated in a federal prison

at the time of trial, was a jailhouse witness and that the trial court was required to include a

jailhouse-witness instruction in its charge under Article 38.075 of the Texas Code of Criminal

Procedure. See TEX. CODE CRIM. PROC. ANN. art. 38.075(a). We disagree.

Section 38.075(a) provides, in relevant part:

A defendant may not be convicted of an offense on the testimony of a person to whom the defendant made a statement against the defendant’s interest during a time

1 TEX. PENAL CODE ANN. § 20.04(b). 2 The three men were Sanford, Sanford’s brother-in-law, Jose Ponse, and Sanford’s friend, Octavious Rhymes.

2 when the person was imprisoned or confined in the same correctional facility as the defendant unless the testimony is corroborated by other evidence tending to connect the defendant with the offense committed.

Id. Testimony from a jailhouse witness “is inherently unreliable due to the inmate’s incentive to

better [her] circumstances.” Phillips v. State, 463 S.W.3d 59, 66 (Tex. Crim. App. 2015).

Consequently, “Article 38.075 was enacted in recognition that incarcerated individuals have an

incentive to provide information against other incarcerated individuals and that this testimony

should be corroborated.” Id.

Since a trial court is required to sua sponte instruct the jury on the “law applicable to the

case,” it is error for the trial court not to include a jailhouse-witness instruction when the

requirements of Article 38.075 are met. Id. at 65 (quoting Oursbourn v. State, 259 S.W.3d 159,

180 (Tex. Crim. App. 2008). However, a trial court is only required to give a jailhouse-witness

instruction when the record shows that the requirements of Article 38.075 have been met. See

Oursbourn v. State, 259 S.W.3d 159, 180 (Tex. Crim. App. 2008) (“If the evidence raises [the]

issue . . . , then the trial court shall instruct the jury [whatever the statute or rule requires].”).

Under the plain language of Article 38.075, a jailhouse-witness instruction is only required

when (1) there is testimony of a person, (2) to whom the defendant made a statement against the

defendant’s interest, (3) during a time when the person was imprisoned or confined in the same

correctional facility as the defendant. See TEX. CODE CRIM. PROC. ANN. art. 38.075(a). In this

case, Smith testified that Wohlford told her that she had sent a text to one of the men who had

3 abducted her husband to get rid of her husband’s cell phone and that she had deleted the text. 3 In

the context of the evidence at trial, this statement was against Wohlford’s interest. Thus, the first

two requirements of Article 38.075 were met.

However, there was no evidence in the record of when or where these statements were

made to Smith by Wohlford. 4 As Wohlford candidly concedes in her brief, “[i]t is not clear from

the trial record when, where, and the circumstances of” Wohlford’s statements to Smith. The

record only shows that Smith was incarcerated in a federal prison at the time of trial, that Wohlford

was not incarcerated in a federal prison, that Smith had had some contact with Wohlford, and that

Wohlford had made the statements to Smith. Thus, there was no evidence in the record that

Wohlford made the statement to Smith “during a time when [Smith] was imprisoned or confined

in the same correctional facility as [Wohlford].” Id.

Consequently, the record does not show that the requirements of Article 38.075 were met,

the jailhouse-witness issue was not raised, and the trial court was not required to include a

jailhouse-witness instruction in its jury charge. We find that the trial court did not err in not

including a jailhouse-witness instruction. Therefore, we overrule Wohlford’s second issue.

3 Other evidence in the case showed that two texts had been sent from Wohlford’s cell phone to the cell phone owned by Octavious Rhymes, one of the men involved in the abduction and murder, at a time shortly after the abduction when law enforcement was pinging Ibarra’s cell phone in an attempt to locate him and the perpetrators. 4 Although the State attempts to bring forth additional evidence in its brief, the parties’ briefs are not a part of the appellate record. In analyzing whether the trial court was required to include a jailhouse-witness instruction, we are limited to whether the evidence in the record at the time of the charge raised the issue. See Oursbourn, 259 S.W.3d at 180.

4 II. The Trial Court’s Error in Failing to Give a Proper Accomplice-Witness Instruction Was Harmless

A. Introduction

Wohlford also complains that the trial court erred in failing to give a proper accomplice-

witness instruction. 5 Wohlford argues that Sanford, who had previously been convicted of the

aggravated kidnapping and murder of Ibarra, was an accomplice as a matter of law and that the

trial court reversibly erred in failing to instruct the jury that Sanford was an accomplice as a matter

of law. The State concedes that the trial court erred, but argues that such error was harmless. We

agree with the State.

B. Standard of Review

We review an alleged error related to an accomplice-witness instruction under the

procedural framework of Almanza. 6 Zamora v. State, 411 S.W.3d 504, 512 (Tex. Crim. App.

2013) (citing Casanova v. State, 383 S.W.3d 530, 533 (Tex. Crim. App. 2012); Herron v. State,

86 S.W.3d 621, 631–32 (Tex. Crim. App. 2002); Medina v. State, 7 S.W.3d 633

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