William A. Harriman v. the State of Texas

Texas Court of Appeals, 2nd District (Fort Worth)·Decided February 12, 2026·No. 02-25-00108-CR·Published

Opinion

In the

Court of Appeals Second Appellate District of Texas at Fort Worth

No. 02-25-00108-CR

WILLIAM A. HARRIMAN, Appellant V.

THE STATE OF TEXAS

On Appeal from the 271st District Court Wise County, Texas

Trial Court No. CR24740

Before Kerr, Birdwell, and Bassel, JJ.

Memorandum Opinion by Justice Bassel

MEMORANDUM OPINION

Appellant William A. Harriman appeals his conviction for driving while intoxicated, third or more. See Tex. Penal Code Ann. §§ 49.04(a), 49.09(b)(2). Raising two appellate issues, Harriman argues (1) that the trial court abused its discretion by admitting the recording of a witness’s 911 call into evidence over his hearsay and Confrontation Clause objections and (2) that the record contains insufficient evidence to establish beyond a reasonable doubt that he had “operated” a vehicle while intoxicated. We affirm.

I. BACKGROUND

In January 2021, Zach Bryden, who at that time was a patrol sergeant with the Wise County Sheriff’s Office, was dispatched to Farm to Market Road 730 just south of Boyd, Texas, after a 911 caller reported a reckless—and likely intoxicated—driver heading northbound in a gold Ford pickup truck. While Officer Bryden was en route, the gold Ford pickup truck swerved into oncoming traffic and collided with a Buick LeSabre, causing significant damage to both vehicles and seriously injuring the driver of the LeSabre.

Officer Bryden arrived on the scene “within seconds of the crash[’s]

happening.” He walked up to the gold Ford pickup truck and spoke to Harriman, who was sitting in the driver’s seat. After Harriman stated that he did not feel any pain, Officer Bryden instructed him to get out of the vehicle and move to a safer location. Officer Bryden did not observe anyone other than Harriman in the vehicle.

Because Harriman appeared intoxicated, smelled of alcohol, admitted that he had been drinking, and failed multiple standard field sobriety tests, he was placed under arrest for driving while intoxicated. After being transported to jail, Harriman agreed to take a breathalyzer test, which revealed his breath–alcohol concentration to be more than twice the legal limit.

Harriman was charged by indictment with driving while intoxicated, third or more; the indictment alleged that Harriman had used his vehicle as a deadly weapon. Harriman pleaded not guilty, and a jury trial was held. After considering all the evidence, the jury found Harriman guilty and also found the indictment’s deadly- weapon allegation to be true. Harriman elected to have the trial court, not the jury, assess his punishment. Following the trial’s punishment phase, the trial court sentenced Harriman to thirty-eight years in prison. This appeal followed.

II. DISCUSSION

A. The Trial Court Did Not Abuse Its Discretion by Admitting the Recording of the 911 Call In his first issue, Harriman contends that the trial court abused its discretion by

admitting over his hearsay and Confrontation Clause objections the recording of the 911 call reporting a drunk driver on Farm to Market Road 730. We disagree.

1. Standard of Review We review a trial court’s decision to admit or exclude evidence under an abuse-

of-discretion standard. Zuliani v. State, 97 S.W.3d 589, 595 (Tex. Crim. App. 2003);

Montgomery v. State, 810 S.W.2d 372, 379 (Tex. Crim. App. 1990). We will not reverse a trial court’s decision to admit or exclude evidence unless the record shows a clear abuse of discretion. Zuliani, 97 S.W.3d at 595. An abuse of discretion occurs only when the trial court’s decision was so clearly wrong as to lie outside that zone within which reasonable persons might disagree. Id.

2. Hearsay Analysis “Hearsay” is a statement, other than one made by the declarant while testifying at trial, offered in evidence to prove the truth of the matter asserted. Tex. R. Evid. 801(d). Hearsay is not admissible unless a statute, a rule of evidence, or another rule prescribed under statutory authority provides otherwise. Tex. R. Evid. 802.

One exception to the hearsay prohibition is a statement of present-sense impression—i.e., “[a] statement describing or explaining an event or condition, made while or immediately after the declarant perceived it.” Tex. R. Evid. 803(1). Here, the caller on the 911 recording was describing Harriman’s driving immediately after he perceived it. Thus, the 911 recording falls within the present-sense-impression exception, and the trial court did not abuse its discretion by overruling Harriman’s hearsay objection. See Kinnett v. State, 623 S.W.3d 876, 911 (Tex. App.—Houston [1st Dist.] 2020, pet. ref’d) (holding that recording of call to police nonemergency number reporting a reckless driver fell within the present-sense-impression exception to the hearsay rule because it described what the caller had witnessed in the immediate past); Reyes v. State, 314 S.W.3d 74, 78 (Tex. App.—San Antonio 2010, no pet.) (holding that

recording of 911 call fell within present-sense-impression exception because statements indicated caller was describing events as they were happening); see also Castillo v. State, 517 S.W.3d 363, 378 (Tex. App.—Eastland 2017, pet. ref’d) (explaining that the rationale for the present-sense-impression exception to the hearsay rule “stems from the statement’s contemporaneity, not its spontaneity,” and concluding that five-minute lapse of time between event and statement “d[id] not destroy the contemporaneity” of the statement).

3. Confrontation Clause Analysis The Sixth Amendment’s Confrontation Clause, applicable to the states through the Fourteenth Amendment, provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him.” Crawford v. Washington, 541 U.S. 36, 38, 42, 124 S. Ct. 1354, 1357, 1359 (2004); Langham v. State, 305 S.W.3d 568, 575 (Tex. Crim. App. 2010) (citing U.S. Const. amend. VI). “[T]he most important instances in which the [Confrontation] Clause restricts the introduction of out-of-court statements are those in which state actors are involved in a formal, out-of-court interrogation of a witness to obtain evidence for trial.” Michigan v. Bryant, 562 U.S. 344, 358, 131 S. Ct. 1143, 1155 (2011). Once a defendant raises a Confrontation Clause objection, the burden shifts to the State to prove either (1) that the proposed statement does not contain testimonial hearsay and thus does not implicate the Confrontation Clause or (2) that the statement does contain testimonial

hearsay but is nevertheless admissible. See De La Paz v. State, 273 S.W.3d 671, 680–81 (Tex. Crim. App. 2008) (citing Crawford, 541 U.S. at 68, 124 S. Ct. at 1374).

“[T]estimonial statements are those ‘that were made under circumstances which would lead an objective witness reasonably to believe that the statement would be available for use at a later trial.’” Adkins v. State, 418 S.W.3d 856, 861–62 (Tex. App.—Houston [14th Dist.] 2013, pet. ref’d) (quoting Burch v. State, 401 S.W.3d 634, 636 (Tex. Crim. App. 2013)). A court considers the totality of the circumstances in determining whether a statement is testimonial. Clark v. State, 282 S.W.3d 924, 931 (Tex. App.—Beaumont 2009, pet. ref’d).

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