Scottie Heath Gibson v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 7, 2024
Docket10-23-00131-CR
StatusPublished

This text of Scottie Heath Gibson v. the State of Texas (Scottie Heath Gibson 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
Scottie Heath Gibson v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-23-00131-CR

SCOTTIE HEATH GIBSON, Appellant v.

THE STATE OF TEXAS, Appellee

From the 18th District Court Johnson County, Texas Trial Court No. DC-F202000027

MEMORANDUM OPINION

Scottie Heath Gibson appeals his convictions for one count of continuous sexual

abuse of a young child, seven counts of sexual assault of a child, and two counts of

indecency with a child. A jury found him guilty and assessed punishment at confinement

in the Texas Department of Criminal Justice—Institutional Division for forty years for

count one, thirty-five years each for counts two and three, and ten years each for counts

four through ten. The trial court ordered that his sentences for counts one, two, and three shall run consecutively, and the sentences for the remainder of the counts shall run

concurrently will all counts. In thirteen issues, Gibson contends the trial court violated

his constitutional rights to a speedy trial, to be free of unreasonable searches and seizures,

and to confront witnesses, the trial court erred in admitting certain evidence, and the

evidence is legally insufficient to support the convictions of any of the ten counts. We

affirm.

Speedy Trial

In his first issue, Gibson contends the trial court violated his constitutional right to

a speedy trial. He complains of a thirty-seven-month delay between his arrest and trial.

He claims he asserted his right to a speedy trial multiple times, and all of the delays were

caused by the State or an overcrowded docket, or were unexplained, resulting in

prejudice and requiring dismissal of the prosecution.

APPLICABLE LAW

An accused is guaranteed the right to a speedy trial under the Sixth Amendment

of the United States Constitution, Article 1, Section 10 of the Texas Constitution, and

article 1.05 of the Texas Code of Criminal Procedure. U.S. CONST. amend. VI; TEX. CONST.

art. I, § 10; TEX. CODE CRIM. PROC. ANN. art. 1.05. In determining whether the accused has

been denied the right to a speedy trial, the court must weigh and balance four factors: (1)

length of the delay; (2) reason for the delay; (3) assertion of the right; and (4) prejudice to

the accused. Barker v. Wingo, 407 U.S. 514, 530 (1972); Dragoo v. State, 96 S.W.3d 308, 313

Gibson v. State Page 2 (Tex. Crim. App. 2003). This balancing test requires weighing case-by-case the conduct

of both the prosecution and the accused. Barker, 407 U.S. at 530.

In reviewing a trial court's decision on a speedy trial claim, the appellate court

gives almost total deference to the trial court's findings of fact that the record supports,

and we draw reasonable inferences from those facts necessary to support the trial court's

findings. Balderas v. State, 517 S.W.3d 756, 767-68 (Tex. Crim. App. 2016). But the

balancing test as a whole is a purely legal question that we review de novo. Id. at 768.

Length of Delay

In general, courts deem delay approaching one year to be "unreasonable enough

to trigger the Barker enquiry." Id. The extent to which the delay exceeded the minimum

needed to trigger judicial examination factors into our assessment of the first Barker

factor. Id. In this case, Gibson was arrested in December 2019 and tried in January 2023,

an interval of about three years. Because this delay stretched far beyond the minimum

needed to trigger the inquiry, the first Barker factor weighs heavily in favor of finding a

violation of Gibson's speedy-trial right. See id.

Reason for the Delay

In assessing the reason for the delay, different weights should be assigned to

different reasons for the delay. Id. Some reasons are valid and serve to justify an

appropriate delay. Id. Deliberate delay intended to hamper the defense weighs heavily

against the State, while more neutral reasons, such as negligence or overcrowded courts,

Gibson v. State Page 3 weigh less heavily. Id. Additionally, we consider whether the government or the

criminal defendant is more to blame for the delay. Id.

Jury trials were either banned or restricted from spring 2020 through early 2021.

See e.g., Seventeenth Emergency Order Regarding the Covid-19 State of Disaster, 609 S.W.3d

119, 120 (Tex. 2020); Thirty-Third Emergency Order Regarding the Covid-19 State of Disaster,

629 S.W.3d 179, 179-80 (Tex. 2021); see also Covid-19 Operating Plan for the Johnson County

Judiciary Guinn Justice Center and Justice of the Peace Offices, May 20, 2020 (prohibiting jury

trials in Johnson County). At the October 6, 2020 hearing on counsel's motion to

withdraw, counsel stated there have been some COVID-related delays. Delay caused by

the onset of the pandemic cannot be attributed as fault to the State. State v. Conatser, 645

S.W.3d 925, 930 (Tex. App.—Dallas 2022, no pet.). At the November 24, 2020 pretrial

hearing, defense counsel asked for a pass until January 14, 2021 because she did not think

anything could be resolved at that hearing. Due to the fact this overlapped with the

Covid delay time period, we decline to weigh it against Gibson.

Additionally, we should not hold the first few months after the arrest against the

State because the State is allowed a reasonable period to prepare its case. See Shaw v.

State, 117 S.W.3d 883, 889-90 (Tex. Crim. App. 2003); Wade v. State, No. 02-21-000125-CR,

2023 Tex. App. LEXIS 1716, at *13 (Tex. App.—Fort Worth March 16, 2023, pet. ref'd)

(mem. op., not designated for publication) (not holding first three months against State);

State v. Echols, No. 11-19-00209-CR, 2021 Tex. App. LEXIS 4219, at *10 (Tex. App.—

Gibson v. State Page 4 Eastland May 28, 2021, pet. ref'd) (mem. op., not designated for publication) (seven

months attributable to State's preparation not held against the State).

Gibson's actions contributed to the delay. On December 12, 2019, the trial court

appointed Gibson's first attorney. On May 24, 2022, the trial court appointed Gibson's

seventh attorney. One attorney withdrew due to a conflict of interest. However, in

motions to withdraw, six of the attorneys cited "fundamental communication" issues,

personality conflicts, Gibson's combativeness, and Gibson's desire to engage in hybrid

representation and inability to take legal advice, barring effective representation. The

trial court could infer that Gibson contributed to the delay because of his inability to

effectively communicate with appointed counsel. See Balderas, 517 S.W.3d at 767-68.

On September 10, 2021, Gibson filed a petition for writ of mandamus in this Court.

At the September 16, 2021 pretrial hearing, the case was reset to January 13, 2022 because

the petition remained pending. See In re Gibson, No. 10-21-00228-CR, 2021 Tex. App.

LEXIS 9192 (Tex. App.—Waco November 10, 2021, orig. proceeding) (mem. op.). Because

Gibson's petition delayed the trial, this delay does not count in support of his speedy trial

claim.1 See United States v. Loud Hawk, 474 U.S. 302, 316 (1986).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
United States v. Loud Hawk
474 U.S. 302 (Supreme Court, 1986)
Crawford v. Washington
541 U.S. 36 (Supreme Court, 2004)
Webb v. State
36 S.W.3d 164 (Court of Appeals of Texas, 2000)
Dragoo v. State
96 S.W.3d 308 (Court of Criminal Appeals of Texas, 2003)
Shaw v. State
117 S.W.3d 883 (Court of Criminal Appeals of Texas, 2003)
Wall v. State
184 S.W.3d 730 (Court of Criminal Appeals of Texas, 2006)
State v. Munoz
991 S.W.2d 818 (Court of Criminal Appeals of Texas, 1999)
McKenzie v. State
617 S.W.2d 211 (Court of Criminal Appeals of Texas, 1981)
Floyd v. State
959 S.W.2d 706 (Court of Appeals of Texas, 1998)
Robinson v. State
240 S.W.3d 919 (Court of Criminal Appeals of Texas, 2007)
Newman v. State
331 S.W.3d 447 (Court of Criminal Appeals of Texas, 2011)
Montgomery v. State
810 S.W.2d 372 (Court of Criminal Appeals of Texas, 1991)
Ranson v. State
707 S.W.2d 96 (Court of Criminal Appeals of Texas, 1986)
Orellana v. State
706 S.W.2d 660 (Court of Criminal Appeals of Texas, 1986)
Donald Ray Wells v. State
558 S.W.3d 661 (Court of Appeals of Texas, 2017)
C.F. v. State
897 S.W.2d 464 (Court of Appeals of Texas, 1995)
Balderas v. State
517 S.W.3d 756 (Court of Criminal Appeals of Texas, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Scottie Heath Gibson v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scottie-heath-gibson-v-the-state-of-texas-texapp-2024.