Texas Department of Public Safety v. James David Latimer

CourtCourt of Appeals of Texas
DecidedFebruary 13, 1997
Docket03-96-00277-CV
StatusPublished

This text of Texas Department of Public Safety v. James David Latimer (Texas Department of Public Safety v. James David Latimer) 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
Texas Department of Public Safety v. James David Latimer, (Tex. Ct. App. 1997).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-96-00277-CV



Texas Department of Public Safety, Appellant



v.



James David Latimer, Appellee



FROM THE COUNTY COURT AT LAW NO. 2 OF TRAVIS COUNTY

NO. 229,160, HONORABLE ORLINDA L. NARANJO, JUDGE PRESIDING



PER CURIAM



Appellant Texas Department of Public Safety challenges a county court at law judgment reversing an administrative order sustaining the suspension of appellee James David Latimer's driver's license. See Tex. Transp. Code Ann. §§ 724.042, .043 (West Supp. 1997). The Department challenges the court's power to reverse an administrative order when the administrative record was not admitted into evidence and also complains that the court erred in reversing the administrative order when the necessary fact findings were supported by substantial evidence. We will reverse the county court at law judgment and render judgment affirming the administrative order.

THE CONTROVERSY

Latimer was involved in a three-car collision on December 11, 1995. He was trapped in his car and had to be removed by the fire department. He was taken to Brackenridge Hospital after he was freed because he was thought to have serious internal injuries.

An Austin police officer interviewed Latimer in the intensive care unit at the hospital. Suspecting that Latimer was intoxicated, the officer requested that Latimer submit to a blood test and, as required by statute, warned Latimer that unless he consented his driver's license would be suspended and that a refusal to submit a blood sample could be admitted into evidence at a later criminal prosecution. See Tex. Transp. Code Ann. § 724.015 (West Supp. 1997). Latimer, who was connected to intravenous tubes and in considerable pain, responded by asking to see his wife.

Unless successfully challenged, a person's driver's license is automatically suspended if that person refuses an officer's request that he or she give a blood or breath sample. Id. § 724.035. A person challenging the automatic suspension of his or her driver's license is entitled to a hearing before an administrative law judge ("ALJ") of the State Office of Administrative Hearings ("SOAH"). Id. § 724.041. At the hearing, the Department must prove by a preponderance of the evidence that reasonable suspicion or probable cause existed to stop or arrest the person; that probable cause existed to believe that the person was operating a motor vehicle in a public place while intoxicated; that the person was placed under arrest by the officer and was requested to submit to the taking of a specimen; and that the person refused to submit to the taking of a specimen on request of the officer. Id. § 724.042. If the ALJ finds in the affirmative on each issue, the suspension order is sustained. Id. § 742.043.

An appeal from the ALJ's decision to sustain the suspension is to the county court at law, if one exists in the county in which the offense occurred and if the county court at law judge is an attorney. Id. §§ 524.041; 724.041(g). The appeal is based on the administrative record certified by SOAH. Id. §§ 524.043; 724.041(g). The manner and scope of review is that specified for cases of substantial evidence review. Tex. Gov't Code Ann. §§ 2001.003(7); 2001.l74 (West Supp. 1997).

In this case, the ALJ found that the Department had met its burden and sustained the suspension. On appeal, the county court at law reversed the ALJ's decision.



ANALYSIS



Texas Government Code section 2001.175(d) provides that, "The party seeking judicial review shall offer, and the reviewing court shall admit, the state agency record into evidence as an exhibit." Tex. Gov't Code Ann. § 2001.175(d) (West Supp. 1997). The Department argues by point of error one that the county court at law erred in rendering an order in the suit for judicial review of the ALJ's order because the administrative record had not been admitted into evidence. We disagree on the basis that the record was effectively admitted into evidence.

The statement of facts clearly shows that the court considered the administrative record in arriving at its decision. Further, both parties treated the record as if it had been admitted into evidence: the Department's and Latimer's attorneys referred to documents admitted and testimony offered at the SOAH hearing. And, finally, the Department did not object to the court's consideration of the administrative record on the basis that it was not in evidence.

A number of cases have held that evidence that is treated by the trial court and the parties as if it had been admitted is, for all practical purposes, admitted. See, e.g., Cornish v. State, 848 S.W.2d 144, 145 (Tex. Crim. App. 1993) (juror information cards referred to by court and parties may be considered in Batson challenge although not formally offered or admitted); Heberling v. State, 834 S.W.2d 350, 355-56 (Tex. Crim. App. 1992) (exhibit placed before jury and referred to by witnesses sufficient to sustain verdict although not formally offered or admitted); Killion v. State, 503 S.W.2d 765, 766 (Tex. Crim. App. 1973) (written stipulations neither offered nor admitted could be considered in support of judgment when statement of facts showed that trial court and parties treated stipulations as if they had been admitted into evidence); Kissinger v. State, 501 S.W.2d 78, 79 (Tex. Crim. App. 1973) (evidence offered but not formally admitted was constructively admitted because trial court relied upon them in rendering judgment); Richardson v. State, 475 S.W.2d 932, 933 (Tex. Crim. App. 1972) (objects offered into evidence and considered by court but not formally admitted were constructively admitted); Pickering v. First Greenville Nat'l Bank, 479 S.W.2d 76, 78 (Tex. Civ. App.--Dallas 1972, no writ) (exhibit that was marked, used and referred to by attorneys, and considered by trial court in rendering its decision was in evidence); Guetersloh v. C.I.T. Corp., 451 S.W.2d 759, 760 (Tex. Civ. App.--Amarillo 1970, writ ref'd n.r.e.) (document produced by plaintiff, inspected by defendant, marked by court reporter, handed to and received by the court, and placed in statement of facts is in evidence); Hamilton v. Waples-Platter Co., 424 S.W.2d 295, 298 (Tex. Civ.

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Related

Heberling v. State
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Killion v. State
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Hamilton v. Waples-Platter Co.
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Lewis v. Metropolitan Savings & Loan Ass'n
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Texas Department of Public Safety v. James David Latimer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-department-of-public-safety-v-james-david-la-texapp-1997.