Zachary Dean Jolliff v. the State of Texas

CourtCourt of Appeals of Texas
DecidedApril 13, 2023
Docket05-21-01159-CR
StatusPublished

This text of Zachary Dean Jolliff v. the State of Texas (Zachary Dean Jolliff 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.

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Zachary Dean Jolliff v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

AFFIRMED and Opinion Filed April 13, 2023

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-21-01159-CR

ZACHARY DEAN JOLLIFF, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 59th District Court Grayson County, Texas Trial Court Cause No. 071936

MEMORANDUM OPINION Before Chief Justice Burns and Justices Smith and Breedlove Opinion by Justice Breedlove Appellant Zachary Dean Jolliff was convicted of burglary of a habitation with

the intent to commit murder or aggravated assault and sentenced to 75 years in

prison. Appellant now appeals, complaining that the State failed to establish a

proper chain of custody for fourteen items admitted into evidence. We affirm the

trial court’s judgment.

I. BACKGROUND

Ariel Holley was severely injured when an attacker broke into her home in the

middle of the night and then attempted repeatedly to break her neck and suffocate her. Holley told police that appellant was the man who attacked her. Appellant was

then indicted for the crime of burglary of a habitation with the intent to commit

(1) murder or aggravated assault (Count One); or (2) sexual assault (Count Two).

He pleaded not guilty, and the case was tried before a jury on December 3, 2021.

At trial, ten of the State’s witnesses testified about the chain of custody for the

fourteen items appellant challenges in this appeal:

 Officer Jacob Shoemate: an officer with the Denison Police Department who responded to Holley’s 911 call.

 Officer Aaron Albarenga: an officer with the Denison Police Department who responded to Holley’s 911 call.

 Ranger Brad Oliver: a Texas Ranger with the Texas Department of Public Safety, now retired, who assisted in the investigation and obtained various evidentiary samples from both victim and appellant.

 Detective Steven Kyle Mackay: a detective with the Denison Police Department who assisted in the investigation.

 Kathleen McRoy: a forensic scientist with the DPS lab who analyzed various hair samples as well as the buttons found at the scene.

 Detective Stuart Prigge: a detective with the Denison Police Department who assisted with the investigation of the case and interviewed appellant and Holley.

 Detective Tom Unerfusser: a detective with the Denison Police Department in the property and evidence room who oversaw the receipt and logging and of the evidence in the case and also supervised the exchange of evidence with the DPS lab.

 Courtney Wassung: a fingerprint analyst with the DPS lab who analyzed the print on the front porch lightbulb in comparison to the known print of appellant.

–2–  Jenna Hamann: a serologist with the DPS lab who examined the victim’s shirt for the presence of bodily fluid.

 Kristen Cossota: a forensic scientist with the DNA section of the DPS lab who conducted DNA analyses on various items of evidence.

The jury found appellant guilty on Count One1 and sentenced him to 75 years

in prison. Appellant filed a motion for new trial on December 28, 2021, asserting

that the verdict was contrary to the law and the evidence. This motion was overruled

by operation of law. TEX. R. APP. P. 21.8.

Appellant appealed the verdict on December 28, 2021. In one issue, appellant

complains that the trial court abused its discretion in admitting physical evidence

where the State failed to establish a proper chain of custody. In response, the State

argues that the trial court did not abuse its discretion in denying appellant’s objection

to the chain of custody because any break in the chain was minor and went to the

weight of the evidence, not its admissibility. Alternatively, the State argues that

even if the trial court erred, the error was harmless.

II. STANDARD OF REVIEW AND APPLICABLE LAW

We review a trial court’s decision to admit or exclude evidence for abuse of

discretion. See Beham v. State, 559 S.W.3d 474, 478 (Tex. Crim. App. 2018);

Gonzalez v. State, 544 S.W.3d 363, 370 (Tex. Crim. App. 2018). A trial court abuses

1 As to Count One, the jury charge did not require the jury to agree unanimously on which specific felony offense other than theft appellant intended to commit, or committed. The jury was only required to agree unanimously that the appellant intended to commit, committed, or attempted to commit murder or aggravated assault. –3– its discretion when its decision lies outside the zone of reasonable disagreement.

Beham, 559 S.W.3d at 478; Gonzalez, 544 S.W.3d at 370.

A chain of custody is conclusively proven if an officer is able to identify that

he or she seized the item of physical evidence, put an identification mark on it, placed

it in the property room, and then retrieved the item being offered on the day of trial.

Morgan v. State, No. 05-94-01004-CR, 1995 WL 259220, at *1 (Tex. App.—Dallas

May 3, 1994, pet. ref’d) (mem. op., not designated for publication) (citing Stoker v.

State, 788 S.W.2d 1, 10 (Tex. Crim. App. 1989), overruled on other grounds by

Horton v. California, 496 U.S. 128 (1990); Luna v. State, 493 S.W.2d 854, 856 (Tex.

Crim. App. 1973); and Elliott v. State, 450 S.W.2d 863, 864 (Tex. Crim. App.

1970)). A chain of custody is sufficiently authenticated when the State establishes

the beginning and the end of the chain, particularly when the chain ends at a

laboratory. Simmons v. State, No. 05-11-01267-CR, 2013 WL 1614114, at *6 (Tex.

App.—Dallas Feb. 20, 2013) (mem. op., not designated for publication) (citing

Martinez v. State, 186 S.W.3d 59, 62 (Tex. App.—Houston [1st Dist.] 2005, pet.

ref’d)). Absent proof of tampering, most problems with the chain of custody do not

affect the admissibility of evidence, but rather go to the weight of the evidence. Id.

(citing Lagrone v. State, 942 S.W.2d 602, 617 (Tex. Crim. App. 1997)).

Further, Texas does not require a showing of chain of custody for admission

of evidence that is readily identifiable. Hammett v. State, 578 S.W.2d 699, 708 (Tex.

Crim. App. 1979), cert. dism’d, 448 U.S. 725 (1980). A chain of custody showing

–4– is required when only scientific tests or analyses can distinguish the evidence’s

relevant characteristics. Davis v. State, 831 S.W.2d 426, 443 (Tex. App.—Austin

1992, pet. ref’d)) (citing Hammett, 578 S.W.2d at 708 and Edlund v. State, 677

S.W.2d 204, 210 (Tex. App.—Houston [1st Dist.] 1984, no pet.)). “The State is not

obligated to prove chain of custody on such items as clothing.” Belcher v. State, 661

S.W.2d 230, 233 (Tex. App.—Houston [1st Dist.] 1983, pet. ref’d) (citing

Hackbarth v. State, 617 S.W.2d 944, 947 (Tex. Crim. App. [Panel Op.] 1981)).

III.

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Related

Hammett v. Texas
448 U.S. 725 (Supreme Court, 1980)
Horton v. California
496 U.S. 128 (Supreme Court, 1990)
Davis v. State
831 S.W.2d 426 (Court of Appeals of Texas, 1992)
Elliott v. State
450 S.W.2d 863 (Court of Criminal Appeals of Texas, 1970)
Lagrone v. State
942 S.W.2d 602 (Court of Criminal Appeals of Texas, 1997)
Anderson v. State
504 S.W.2d 507 (Court of Criminal Appeals of Texas, 1974)
Hackbarth v. State
617 S.W.2d 944 (Court of Criminal Appeals of Texas, 1981)
Bird v. State
692 S.W.2d 65 (Court of Criminal Appeals of Texas, 1985)
Hammett v. State
578 S.W.2d 699 (Court of Criminal Appeals of Texas, 1979)
Belcher v. State
661 S.W.2d 230 (Court of Appeals of Texas, 1984)
Martinez v. State
186 S.W.3d 59 (Court of Appeals of Texas, 2006)
Luna v. State
493 S.W.2d 854 (Court of Criminal Appeals of Texas, 1973)
Anderson v. State
717 S.W.2d 622 (Court of Criminal Appeals of Texas, 1986)
Stoker v. State
788 S.W.2d 1 (Court of Criminal Appeals of Texas, 1989)
Edlund v. State
677 S.W.2d 204 (Court of Appeals of Texas, 1984)
Clark v. State
365 S.W.3d 333 (Court of Criminal Appeals of Texas, 2012)
Gonzalez v. State
544 S.W.3d 363 (Court of Criminal Appeals of Texas, 2018)
Beham v. State
559 S.W.3d 474 (Court of Criminal Appeals of Texas, 2018)

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