William Henderson v. the State of Texas

CourtCourt of Appeals of Texas
DecidedOctober 10, 2023
Docket01-23-00056-CR
StatusPublished

This text of William Henderson v. the State of Texas (William Henderson v. the State of Texas) 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
William Henderson v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

Opinion issued October 10, 2023

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00056-CR ——————————— WILLIAM HENDERSON, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 149th District Court Brazoria County, Texas Trial Court Case No. 96103-CR

MEMORANDUM OPINION

William Henderson pleaded guilty to the offense of evading arrest and was

sentenced to 12 years’ imprisonment. On appeal, he argues the trial court violated

his constitutional rights by assessing a punishment that is grossly disproportionate

to the crime committed. We affirm. BACKGROUND

David Morse was caught shoplifting from an H-E-B grocery store in August

of 2021. As he was leaving the store, a store employee asked to see his receipt, and

he fled to the parking lot. He jumped into the backseat of a car in the parking lot that

Henderson, the appellant, was driving. Other nearby customers saw what was

happening and tried to pull Morse out of the backseat, unsuccessfully. Henderson

then sped out of the parking lot and onto State Highway 288.

A police officer located the car Henderson was driving and turned on his

emergency lights. Henderson continued to speed away from the officer for the next

15 minutes, traveling at speeds between 90 to 120 miles per hour and at times

crossing into the lane of oncoming traffic to pass other vehicles on the road. The

chase ended when Henderson ran a red light and crashed into a box truck. Henderson

got out of the car and ran away, and he was apprehended about a year later.

Henderson was indicted for the offense of evading arrest and pleaded guilty.

He also pleaded “true” to the enhancement of a prior felony conviction for burglary

of a habitation, which increased the offense from a third-degree felony to a second-

degree felony. He requested that the trial court sentence him. After a punishment

hearing, the trial court sentenced Henderson to 12 years’ imprisonment in the Texas

Department of Criminal Justice–Institutional Division.

2 Cruel and Unusual Punishment

In his sole issue on appeal, Henderson contends that his punishment is grossly

disproportionate to the crime he committed and violates the United States and Texas

Constitutions’ prohibitions against cruel and unusual punishment. Specifically, he

argues his sentence was grossly disproportionate for four reasons: (1) he has a

limited criminal history of one prior burglary conviction that occurred more than 14

years ago; (2) no one was seriously injured in the collision; (3) he spent over six

months in jail awaiting resolution of his charge; and (4) he pleaded guilty to the

charged offense and accepted responsibility for his actions. The State contends that

Henderson failed to preserve his complaint for appellate review because he did not

make a specific objection in the trial court.

Applicable Law

Both the United States and Texas Constitutions prohibit cruel and unusual

punishment. U.S. CONST. amend. VIII; TEX. CONST. art. I § 13. Generally, these

provisions require a punishment to be proportional to the crime committed. Solem v.

Helm, 463 U.S. 277, 290 (1983); Cantu v. State, 939 S.W.2d 627, 645 (Tex. Crim.

App. 1997) (interpreting state constitution’s provision coextensively with federal

counterpart despite minor difference in wording). These provisions do not require

strict proportionality, however; they only prohibit extreme sentences that are

“grossly disproportionate” to the crime. State v. Simpson, 488 S.W.3d 318, 322 (Tex.

3 Crim. App. 2016) (quoting Ewing v. California, 538 U.S. 11, 23 (2003) (plurality

opinion)). A punishment will be grossly disproportionate only in “exceedingly rare”

or “extreme” cases. Id. at 322–23. Typically, a punishment within the prescribed

statutory range of punishment for an offense is not grossly disproportionate, cruel,

or unusual. See id. at 323.

Most complaints, even constitutional errors, can be waived on appeal if not

raised in the trial court. Garza v. State, 435 S.W.3d 258, 260–61 (Tex. Crim. App.

2014); see also Curry v. State, 910 S.W.2d 490, 497 (Tex. Crim. App. 1995) (holding

defendant waived complaint concerning cruel and unusual punishment by not

objecting at trial); Noland v. State, 264 S.W.3d 144, 151–52 (Tex. App.—Houston

[1st Dist.] 2007, pet. ref’d) (holding defendant failed to preserve Eighth Amendment

complaint for appeal by not objecting to punishment at trial or asserting complaint

in new-trial motion); Wynn v. State, 219 S.W.3d 54, 61 (Tex. App.—Houston [1st

Dist.] 2006, pet. ref’d) (holding defendant’s failure to object to sentence as cruel and

unusual or raise argument in new-trial motion waived error); Solis v. State, 945

S.W.2d 300, 301 (Tex. App.—Houston [1st Dist.] 1997, pet. ref’d) (holding

defendant could not assert cruel and unusual punishment for first time on appeal and

waived error by not objecting in trial court).

Generally, to preserve a complaint for appellate review, the record must show

that the defendant made the complaint to the trial court by “timely request, objection,

4 or motion” stating the grounds for the complaint with “sufficient specificity to make

the trial court aware of the complaint” and that the trial court either ruled or refused

to rule on the request, objection, or motion. TEX. R. APP. P. 33.1(a). To preserve a

complaint of cruel and unusual punishment, a defendant must either object when the

sentence is assessed or raise the issue in a motion for new trial. See Guillory v. State,

652 S.W.3d 923, 929–30 (Tex. App.—Eastland 2022, pet. filed); Noland, 264

S.W.3d at 151; Wynn, 219 S.W.3d at 61. The purpose of the preservation-of-error

rule is to ensure the trial court has an opportunity to correct the error. Adair v. State,

673 S.W.3d 348, 352 (Tex. App.—Corpus Christi–Edinburg 2023, no pet.). Simply

filing a notice of appeal is not sufficient to preserve error because it does not give

the trial court an opportunity to reconsider the proceedings to correct any error. Id.

We should not address the merits of an issue that has not been preserved for

appeal. Ford v. State, 305 S.W.3d 530, 532 (Tex. Crim. App. 2009).

Analysis

The State argues Henderson waived his complaint of cruel and unusual

punishment by not raising his complaint with sufficient specificity before the trial

court and by not filing a motion for new trial.

The record shows that at the end of the punishment hearing, Henderson

accepted the trial court’s sentence without objection:

5 THE COURT: I’m going to assess your punishment at 12 years in the Texas Department of Criminal Justice Institutional Division. . . . Do you have any legal reason why [this] sentence should not be assessed?

THE DEFENDANT: No.

THE COURT: Okay.

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Related

Solem v. Helm
463 U.S. 277 (Supreme Court, 1983)
Ewing v. California
538 U.S. 11 (Supreme Court, 2003)
Wynn v. State
219 S.W.3d 54 (Court of Appeals of Texas, 2006)
Noland v. State
264 S.W.3d 144 (Court of Appeals of Texas, 2008)
Curry v. State
910 S.W.2d 490 (Court of Criminal Appeals of Texas, 1995)
Ford v. State
305 S.W.3d 530 (Court of Criminal Appeals of Texas, 2009)
Solis v. State
945 S.W.2d 300 (Court of Appeals of Texas, 1997)
Cantu v. State
939 S.W.2d 627 (Court of Criminal Appeals of Texas, 1997)
Simpson, Mark Twain
488 S.W.3d 318 (Court of Criminal Appeals of Texas, 2016)
Garza v. State
435 S.W.3d 258 (Court of Criminal Appeals of Texas, 2014)

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William Henderson v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-henderson-v-the-state-of-texas-texapp-2023.