Tammy Rose Wiggins v. State

CourtCourt of Appeals of Texas
DecidedNovember 18, 2004
Docket06-03-00216-CR
StatusPublished

This text of Tammy Rose Wiggins v. State (Tammy Rose Wiggins 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
Tammy Rose Wiggins v. State, (Tex. Ct. App. 2004).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana


______________________________


No. 06-03-00216-CR



TAMMY ROSE WIGGINS, Appellant

V.

THE STATE OF TEXAS, Appellee




On Appeal from the 115th Judicial District Court

Marion County, Texas

Trial Court No. F13,266





Before Morriss, C.J., Ross and Carter, JJ.

Opinion by Justice Carter



O P I N I O N


            Tammy Rose Wiggins was convicted of capital murder and sentenced to life in prison. Her only complaint on appeal is that the admission of hearsay statements made by her co-conspirator, Glen Bethany, to testifying witnesses Mark Fish, Teresa Miller, and Wendy Bunn Troquille, violated her Confrontation Clause rights as articulated in Crawford v. Washington, 124 S.Ct. 1354 (2004). Finding the co-conspirator statements on which she bases her appeal nontestimonial, we overrule Wiggins' three points of error and affirm the trial court's judgment.

            Wiggins does not attack the sufficiency of evidence at trial, so a detailed recitation of the facts of this case is not necessary. An in-depth summary of the evidence of this crime may be found in this Court's opinion in Bethany v. State, 06-03-00185-CR.

            In brief, the evidence adduced at trial showed that Tammy was involved in an extra-marital affair with Bethany. Tammy and Bethany conspired to kill Tammy's husband, Randy Wiggins. Randy had filed for divorce from Tammy and intended to seek custody of their young child. In exchange for his help in the murder, Bethany was to receive from Tammy the title to Randy's Lincoln automobile. Randy and Tammy left a bar near the Louisiana/Arkansas/Texas state lines, and pulled off the road near an oil well in Cass County, Texas. Bethany waited there until Tammy and Randy arrived, then Bethany hit Randy at least twice in the head with a hammer, and cut Randy's throat. Bethany put Randy's body in a large toolbox in a pickup truck Bethany had stolen; Bethany dumped the body on a county road in Marion County, then took the truck to Frierson, Louisiana, and set it ablaze.

Co-Conspirator Statements

            The evidence on which Tammy bases her Crawford complaints is as follows:

            Teresa Miller was the live-in girlfriend of Mark Fish at the time of Randy's murder. She testified that Bethany and Tammy stayed with Miller and Fish. Miller heard Bethany and Tammy, in Miller's kitchen, talking about Bethany getting the title to Randy's car in exchange for killing Randy. Miller, while in the car with Tammy and Bethany, heard Tammy ask Bethany to kill Randy so Tammy and Bethany "could be together." Miller did not hear Bethany respond to Tammy's statement, but did hear Tammy say that, if Bethany did not kill Randy, Tammy would do it herself. After Tammy got out of the car, Bethany told Fish and Miller he would not kill "any man for a woman."

            Miller also said that Bethany told her specifics about the murder and that he asked her to take him to recover the hammer used in the killing. After seeing coverage of Randy's death on the local news, Bethany asked if Miller knew who the victim was. After Miller answered that she did not know him, Bethany told her the victim was Tammy's husband. He described to Miller that Tammy and Randy left a bar and came to a clearing in the woods, where Bethany waited. Bethany said he struck Randy in the head with a ball peen hammer, stabbed him, cut his throat, put his body in the toolbox, drove seventy-five miles away, and dumped the body. He took the title to the Lincoln from Randy's wallet. Bethany then put his bloody clothes in the front of the truck, took the truck to another location, and burned it. The description Bethany gave of the murder had not been mentioned on the news broadcasts. After telling all this to Miller, he asked her to go with him to look for the hammer.

            Fish testified Bethany described the murder, using hand gestures to indicate cutting motions to the throat. Bethany said the song, "Three Times a Lady" was his code for the murder, because he had cut Randy's throat three times. Bethany asked Fish to help provide an alibi for Bethany and Tammy. Fish testified he heard Bethany and Tammy talking in the kitchen; Bethany later told Fish he had been "coaching" Tammy in case she was questioned by police detectives.

            Troquille testified that Bethany told her specifics about the murder event and that he asked her to take him to recover the hammer used in the killing. Bethany told her the murder had been planned and Tammy had asked him to participate. According to Troquille, Bethany said he waited at a prearranged site, where Tammy arrived with Randy. Bethany said he struck Randy in the head with a ball peen hammer, and the hammer flew out of his grip after the second blow. Bethany told Troquille that "he was not going down for this crime alone" and afterward sent Tammy back to the bar to establish an alibi. Bethany did not ask for Troquille's help in formulating an alibi, but said that, if she would take him back to the murder scene and look for the hammer, she "would never have to work another day in [her] life." Troquille said that the details Bethany told her had not been mentioned on television news reports and that he had thrown in a lake the knife used in the crime.

Nontestimonial Statements Not Barred by Crawford v. Washington

            Wiggins's sole complaint is that the statements made by Bethany to Fish, Miller, and Troquille are barred by Crawford. We disagree. The United States Supreme Court in Crawford held that the Confrontation Clause in the Sixth Amendment to the United States Constitution barred from admission into evidence testimonial statements of a witness who did not appear for trial unless the witness was unavailable to testify and the defendant had had a prior opportunity for cross-examination. Crawford, 124 S.Ct. at 1365. Crawford concerns testimonial statements. Co-conspirator statements made in the furtherance of a conspiracy are nontestimonial. Crawford, 124 S.Ct. at 1367 ("[m]ost of the hearsay exceptions covered statements that by their nature were not testimonial—for example, business records or statements in furtherance of a conspiracy"); United States v. Reyes, 362 F.3d 536, 541 (8th Cir.), cert. denied, Burton v. United States, 124 S.Ct. 2926 (2004).

             Appellant is correct that Crawford "leave[s] for another day . . . a comprehensive definition of 'testimonial.'" Crawford, 124 S.Ct. at 1374. However, the Court did note that "the term covers . . . at a minimum . . . prior testimony at a preliminary hearing, before a grand jury, or at a former trial; and . . . police interrogations.

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