State v. Cristela Garcia

CourtCourt of Appeals of Texas
DecidedDecember 15, 2011
Docket13-09-00506-CR
StatusPublished

This text of State v. Cristela Garcia (State v. Cristela Garcia) 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
State v. Cristela Garcia, (Tex. Ct. App. 2011).

Opinion

NUMBER 13-09-00506-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

EX PARTE CRISTELA GARCIA

On appeal from the 449th District Court of Hidalgo County, Texas.

MEMORANDUM OPINION ON REMAND Before Chief Justice Valdez and Justices Rodriguez and Garza Memorandum Opinion on Remand by Justice Garza This case is before us on remand from the Texas Court of Criminal Appeals.

Appellee, Cristela Garcia, filed an application for writ of habeas corpus alleging that her

guilty plea to felony theft twenty-five years ago was involuntary. See TEX. CODE CRIM.

PROC. ANN. art. 11.072 (West 2005). The trial court granted relief. This Court reversed,

finding that appellee’s testimony alone was insufficient to support the trial court’s ruling.

See State v. Garcia, No. 13-09-00506-CR, 2010 Tex. App. LEXIS 7119, at *13 (Tex.

App.—Corpus Christi Aug. 31, 2010) (mem. op., not designated for publication), rev’d

by Ex parte Garcia, No. PD-1658-10, 2011 Tex. Crim. App. LEXIS 1161, at *11 (Tex. Crim. App. Sept. 14, 2011).

The court of criminal appeals reversed, holding that ―an applicant’s live, sworn

testimony can be a basis for upholding a trial court’s decision to grant relief in an article

11.072 habeas proceeding.‖ See Garcia, 2011 Tex. Crim. App. LEXIS 1161, at *11.

The court of criminal appeals remanded the case to this Court to decide: (1) ―whether

appellee’s testimony was in fact a sufficient basis for upholding the trial court’s

decision,‖ and (2) whether appellee’s claim for habeas relief is barred by the doctrine of

laches. See id. We affirm the trial court’s judgment.

I. BACKGROUND

We adopt the background facts as stated by the court of criminal appeals:

In 1986 at the age of 18, appellee pled guilty to theft of property valued at more than $750 and less than $20,000, a third-degree felony. She was sentenced to five years, but imposition of that sentence was suspended and she was placed on probation. She was released from probation in 1990. In 2009, she filed an application for habeas corpus under article 11.072 [of the code of criminal procedure], alleging that her plea was involuntary because she did not know that she was being prosecuted as an adult and was too confused and immature to understand the court's admonishments or the consequences of her plea.

At an evidentiary hearing on her writ application, appellee testified that when she pled guilty she believed she was doing so as a juvenile, she did not understand the consequences of her plea, and she was instructed by her counsel just ―to sign and that [she would] get probation.‖ She further testified that she learned of her status as a felon only when she was denied an application to carry a concealed handgun. She also explained that, since her guilty plea, she had served as a juror on two or three occasions and was a state notary. The State explained that the presiding judge from the 1986 guilty plea had since died and the reporter's records no longer existed.

The trial court entered findings of fact and conclusions of law in appellee's favor and granted relief.

Id. at **1–3.

The trial court entered the following findings of fact and conclusions of law: 2 1. Despite the approximate 23 year period that has elapsed since the Applicant's plea of guilty in 1986, Applicant sought relief and filed her Application for Writ herein in a timely fashion and with reasonable diligence. Applicant was unaware of her felony adult conviction until she was recently advised of the such [sic] when she applied for a concealed weapon license, approximately three months prior to the filing [of] her Application herein. Applicant's lack of knowledge of her conviction is supported by her unchallenged testimony that she has served on three Hidalgo County juries since her plea, including criminal juries wherein defendants were found guilty. The Applicant had a prior juvenile history and a prior misdemeanor adult conviction at the time of her plea in 1986, however, the 139th District Court, like all other Hidalgo County District Courts at the time, handled both juvenile and adult felony proceedings, and that there is merit to Applicant's testimony that she believed she was being processed as a juvenile at the time of her plea. Additionally, although much time has passed since the plea in 1986, the State provided no evidence to show that the State is prejudiced by the setting aside of the plea, judgment and sentence. There is no evidence that the State's case could not be presented in a new trial. For the aforementioned reasons, Applicant's claim is not barred by the equitable doctrine of laches.

2. Applicant's plea of guilty was made involuntarily, unintelligently, and unknowingly. In addition to believing that she was being processed as a juvenile, at the time of the plea, Applicant was a high[–]school student who mechanically followed her attorney'[s] request to sign and plea[d] as he directed because she was going to be on probation. Attributable to her status as a high[–]school student, history with juvenile probation, immaturity and drug use, Applicant's plea of guilty was made pursuant to her limited understanding that she would get probation on a juvenile case. Applicant therefore was unaware that she was going to have an adult felony conviction, said conviction being a direct consequence of her plea.

3. The Court has considered the case law submitted by the State in reference to the presumption of regularity and the Applicant's burden of proof. However, unlike Wilson, Brown, Reeves, and Young, Applicant's complaint is not about the regularity of the proceedings as much as it is about her basic misunderstanding of what kind of proceeding it was. Ex parte Wilson, 716 S.W.2d 953 (Tex. Crim. App. 1986); Brown v. State, [917] S.W.2d 387 (Tex. App.—Fort Worth 1996, no pet.); Reeves v. State, 500 S.W.2d 648 (Tex. Crim. App. 1973); Ex parte Young, 479 S.W.2d 45 (Tex. Crim. App. 1972). Additionally, unlike Wilson, Brown, Reeves, and Young[,] Applicant has provided evidence beyond the plea proceedings to support her argument that her plea was involuntary. Here, the Court particularly finds Applicant's unchallenged testimony that she has served as a convicting criminal juror since her plea to be compelling and credible evidence that she was unaware of her conviction at the time of her plea.

3 Based on its findings and conclusions, the trial court entered the following order:

―Having considered the pleadings, the record, and arguments of counsel, the Court

HEREBY FINDS that Applicant's plea of guilty was made involuntarily, unintelligently,

and unknowingly. Applicant's requested relief is proper and should be GRANTED.‖

II. EVIDENCE SUPPORTING TRIAL COURT’S RULING

A. Standard of Review and Applicable Law

We first address, as the court of criminal appeals instructed, ―whether appellee’s

testimony was in fact a sufficient basis for upholding the trial court’s decision.‖ Id. at

*11. An appellate court reviewing a trial court's ruling on a habeas claim must review

the record evidence in the light most favorable to the trial court's ruling and must uphold

that ruling absent an abuse of discretion. Kniatt v. State, 206 S.W.3d 657, 664 (Tex.

Crim. App. 2006).

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

Related

Walters v. Scott
21 F.3d 683 (Fifth Circuit, 1994)
Kniatt v. State
206 S.W.3d 657 (Court of Criminal Appeals of Texas, 2006)
Ex Parte Young
479 S.W.2d 45 (Court of Criminal Appeals of Texas, 1972)
Ex Parte Wilson
716 S.W.2d 953 (Court of Criminal Appeals of Texas, 1986)
Reeves v. State
500 S.W.2d 648 (Court of Criminal Appeals of Texas, 1973)
Ex Parte Carrio
992 S.W.2d 486 (Court of Criminal Appeals of Texas, 1999)
Guzman v. State
955 S.W.2d 85 (Court of Criminal Appeals of Texas, 1997)
Ex Parte Cristela GARCIA, Appellee
353 S.W.3d 785 (Court of Criminal Appeals of Texas, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Cristela Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cristela-garcia-texapp-2011.