Sonya Faye Zanes v. the State of Texas

Texas Court of Appeals, 1st District (Houston)·Decided August 11, 2026·No. 01-24-00745-CR·Published

Opinion

Opinion issued August 6, 2026

In The

Court of Appeals

For The

First District of Texas

place. Zanes filed a motion for new trial alleging ineffective assistance of trial counsel, which was denied after a hearing. On appeal, Zanes argues she received ineffective assistance of trial counsel and appellate counsel in presenting the motion for new trial. We affirm.

Background

Zanes was pulled over for driving 70 miles per hour in a 60 mile per hour zone. At the time, her ten-year-old grandson was in the front passenger seat.2 The officer noticed that Zanes’s speech was slurred and “thick-tongued.” He did not smell alcohol, so he asked Zanes if she had taken any medication. She admitted to taking her anxiety medication about 20 minutes before she was stopped. The officer’s body and dash camera footage showed that during the traffic stop, Zanes displayed signs of impairment during standardized field sobriety tests. She also struggled to follow instructions and maintain her balance.

Zanes was arrested and a warrant to test a sample of her blood yielded results showing the presence of phentermine, clonazepam, codeine, and delta-THC. After reviewing the video footage, police reports, and toxicology lab results, the State’s drug recognition expert opined that the clonazepam in Zanes’s system correlated to the impairment symptoms she displayed in roadside testing.

2 The disputed element of the offense at trial was whether Zanes was intoxicated. The grandson’s presence in the car and his age were undisputed.

Zanes’s husband testified for the defense. He said that Zanes recently had her front teeth pulled, and the missing teeth caused her to have trouble speaking clearly. He also testified that Zanes had consulted a doctor about lowering her clonazepam dosage because it was making her too lethargic, and the doctor had cut the dose in half. He was surprised by the report that Zanes had told the responding officer that she had taken double her dose. Zanes’s husband said that when pulled over, Zanes had just picked up her grandson from school because he was suspended.

The State argued that Zanes understood the effects of her medications and chose to drive with her grandson in the car anyway. The defense did not dispute that Zanes had taken medication but contended that she was not intoxicated. According to the defense, Zanes’s behavior stemmed from stress and anxiety related to her grandson’s school conduct. The jury found Zanes guilty.

Zanes filed a motion for new trial alleging ineffective assistance of counsel.

The motion was denied after a hearing. Zanes appealed.

Ineffective Assistance of Trial Counsel Zanes argues that she received ineffective assistance from her trial counsel.

We address each allegation of ineffectiveness in turn. A. General Standards for Ineffective Assistance of Counsel To prove she received ineffective assistance of counsel, a defendant must show (1) her counsel’s performance was deficient, and (2) the deficiency prejudiced

the defense. Smith v. State, 286 S.W.3d 333, 340 (Tex. Crim. App. 2009) (citing Strickland v. Washington, 466 U.S. 668, 687 (1984)). The first Strickland prong requires a defendant to establish her trial counsel’s performance fell below an objective standard of reasonableness in light of prevailing professional norms and the necessity of the case. Id. Review of a claim of ineffective assistance of counsel is highly deferential. Strickland, 466 U.S. 689. “The defendant must overcome the strong presumption that counsel’s conduct fell within the wide range of reasonable professional assistance and that the conduct constituted sound trial strategy.” Prine v. State, 537 S.W.3d 113, 117 (Tex. Crim. App. 2017) (citation and internal quotation omitted).

B. The trial court did not abuse its discretion in overruling Zanes’s motion for new trial.

The trial court did not abuse its discretion in overruling Zanes’s motion for new trial. On appeal and in the motion for new trial and hearing, she argues that trial counsel was ineffective because he failed to call an expert witness, failed to investigate evidence and witnesses from her grandson’s school, failed to adequately consult with her before trial, and failed to adequately cross-examine the responding officer.

1. Standard of Review on Zanes’s Motion for New Trial Ineffective assistance of counsel may be raised in a motion for new trial. See Smith, 286 S.W.3d at 340. We review the trial court’s ruling on such a motion under

an abuse of discretion standard, reversing “only if the trial court’s ruling was clearly erroneous and arbitrary.” Okonkwo v. State, 398 S.W.3d 689, 694 (Tex. Crim. App. 2013). An abuse of discretion occurs when no reasonable view of the record would support the trial court’s ruling. Id. In applying this standard, we review the evidence in the light most favorable to the trial court’s ruling on the motion for new trial. State v. Thomas, 428 S.W.3d 99, 104 (Tex. Crim. App. 2014). The trial court, as factfinder, is the sole judge of witness credibility at a new-trial hearing. Okonkwo, 398 S.W.3d at 694. In the absence of express findings, we presume that the trial court made all findings in favor of the prevailing party. Id. We impute implicit factual findings that support the trial court’s ultimate ruling on the motion for new trial when such implicit factual findings are supported by the record. Id.

2. Evidence at the Motion for New Trial Hearing During the hearing on the motion for new trial, Zanes testified that she told her counsel that when she picked up her grandson, she spoke to a school resource officer, a secretary, and a principal, but her counsel did not call these witnesses or obtain the video surveillance of her time at the school. She also testified that her counsel was ineffective for failing to consult a toxicology expert regarding the effects of her prescribed medications and her reported use of CBD cream to manage hand pain. Zanes testified that her counsel did not adequately consult with her

leading up to trial. He neither met outside of the courtroom nor reviewed the field sobriety test videos with her.

Trial counsel testified that he met with Zanes multiple times before trial, including in the courtroom and library and contacted her regularly by phone and text. He was standby counsel when she represented herself, and he took over as lead counsel about a year before trial. Trial counsel did not contact individuals with the school or obtain school surveillance video because he did not think it would help Zanes’s case. Trial counsel did not seek a toxicology expert because he had learned from Zanes’s family members that she smoked marijuana, and he wanted to avoid cross-examination on that topic.

At the conclusion of testimony during the hearing, the trial court asked Zanes’s counsel about the allegation in the motion for rehearing that an officer had told Zanes during the booking process that he thought she was no longer impaired but that it was too late to change course. Counsel informed the court that he found no evidence to corroborate what Zanes told him.

At the end of the hearing, the trial court denied the motion. The trial court declined to speculate whether the witnesses that trial counsel did not call would have been favorable to Zanes’s defense and agreed that no evidence presented at the hearing showed that the arresting officer said Zanes was no longer intoxicated during the booking process.

3. The trial court’s Strickland findings were not an abuse of discretion.

After reviewing the transcript of the motion for new trial hearing, we find no abuse of discretion in the trial court’s conclusion that the record failed to show ineffective assistance of counsel. We address each ground alleged in the motion.

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