Menniefee, Kevin

,; Kevin s. Menniefee 1727174 - Ellis Unit 1697 FM 980 .RECEIVED IN Huntsville, Texas 77343 COURT OF CRIMINAL APPEALf June :7 , 2016 JUN 13 2016 Mr. Abel Acosta, Appeal Clerk COURT OF CRIMINAL APPEALS 12308 Capitol Station Supreme Court Building A~stin, Texas 787~1 Re: Cause No. 287~36C-81> Writ of Mandmaus near Mr. Acosta, Appeal Clerk: Please find enclosed Relator's Writ of Mandmaus to be filed among the papers in the above number and cause. By copy of this letter, I am forwarding a copy of the same to the district Clerk of Kaufman County, Texas. Thank you for your time and consideration in this matter. Sincerely, _ • ~ ~~ KEVIN S. MENNIEFEE - ReJ.a tor Pro SE This document contains some files cc: Mr~ Rhonda Hughey pagr:s that are of poor quality · District Clerk at the time of imaging. County Courthouse 100 w. Mulberry St. Kaufman, Texas 751~2 .. No. IN THE TEXAS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS KEVIN SHARONE MENNIEFEE § Relator, § § Vs. § No.: 2 87136C-86 § The ~th Judicial District § Court of Kaufman County, Texas§ Respondent. § § APPLICATION FOR WRIT OF MANDAMUS, PURSUANT TO RULE 52.8(c), TEX. RULE OF APPELLATE PROCEDURE, DIRECTING THE 86th JUDICIAL DISTRICT COURT TcO PROCESS RELATOR'S APPLICATION FOR WRIT OF HABEAS CORPUS PURSUANT TO V.A.C;.C.P. ART. 11.07 TO THE HONORABLE JUDGES OF SAID APPEAL COURT: COMES NOW, KEVIN SHARONE MENitllriEFEE, TDC No. # 1727174, Pro Se Relator, and files this,: Application for WRit of Mandamus requesting this court to direct the 86rd Judicial District Court of Kaufman County, Texas to process his State aplication for writ of Habeas Corpus pursuant to V.A.C.C.P. art. 11.07 in cause number 28736C-86, presently pending before the Respondent •. In support thereof, Relator will show the following: I. JURISIDCTION This court has jurisdiction to issue a "Writ of Man- amus" in this case pursuant to article 5 § V of the Texas Constitution. Landford v. Fourteenth Court of Appeals, 847 s.w. 581 (Tex. Cir. 11993). MOreover, purpose of ,(1978) Amend- ment to provision of Texas Constitution governing power of Court of Criminal Appeals to issue extraordinary writs; -1- was to confer upon the Court of Criminal Appeals additional power to grant extraordinary writs in cases regarding "Criminal matters". Vernon's Ann. Canst., Art~ 5 § v., State Ex Rel. Vance v. Routt, 5:71 s.w. 2d. 90,':3' (Tex. Crim. App. 1l978). II. STATEMENT OF THE CASE Upon receipt of an application for writ of Habeas Corpus challenging a final felony conviction, the attorney representing the State has (15) days to respond. See, Tex. Code Crim. Proc., art. i1~07,§(b). After the expiration of the time allowed for the State to respond, the trial court is allowed (20) days to determine whether the application contain allegations of controverted, previously unresolved facts material to the 'legality of the applicant's confinement. See, art. 11.1. 07, § 3(c)~ If the trial court determine that the application for writ of Habeas Corpus presents such issues it shall enter an order within 20 days of the expiration of the time allowed for the State to reply designating the issues of fact to resolved~ n. Thus, the trial court has 35 days to enter an order designating issue after the filing date of an ll.G7 application for a writ of Habeas Corpus. Article mt~07 does not authorize the trial court to extend the time limitation imposed by the statute, other than by a •timely• entry of an order designating issues. See, McCree v. Hampton, 824 s-..w. 2tl 578, 579 (Tex. Crim~ App. ll992)(emphasis added). -2- Without a timely entry of an order designating the issue, article 11.07 imposed a duty upon the clerk of the trial court to "immediately" transmit to the Court of Criminal Appeals the record from the application for a writ of Habeas Corpus, deeming the trial court's inaction a finding that no issue of fact require further resolution. See, article 11 • 07, § 3 ( c ) • In this case, Relator filed his State Application for writ of Habeas Corpus by certified mail, certified mail number 7013-1710-0001-0996-9451 January 28, 2016. The Dis- trict CLerk Office stample marked the date of February 2, 2016;. See Cover letter marked as exhibit A attached: On March 04, 2016, Mr. Rhonda Hughey, the District Clerk of Kaufman County, Texas wrote Applicant a letter informing Applican~ that the writ ~f Habeas Corpus was forwarded to the Court of Criminal Appeal. See, exhibit B attached: From March 04, 2016 Applicant was thinking that his State Application was filed in the Texas Court of Criminal Appeal which Mr. Hughey has fabricated a letter statingthat his writ was send to the Court of Criminal Appeals. See, exhibit B; The district clerk, Mr. Hughey, wilful, negligent, incompetence, f~ilure of duty, unprofessional conduct, fraud and misrepresentation of office duty. See, Govern..: ment Code 51.303(e)(2). -3- The Distirct Clerk's forwarding of State Writ to the Court of Criminal Appeal was mandatory, ministerial duty, and applicant had no other adequate remedy, such that mandamus would issue to compel clerk to perform this duty. V.T.C.A~ Government Code § 22.221(a); such is necessary to enforce the Court of Criminal Appeal. In Re Coronoado, 980 s.w. 2d 691, 692 (Tex. App. ~ San Antonio 1998, Orig Proceeding); Summit Saving Ass'n v. Garcia, 727 s.w. 2d. 106, 107 Tex. App. - San Antonio 198~, Orig Proceeding. A Mandamus is proper issues in this case because the record establishes (1) a clear abuse of discretion and a violation of a duty imposed by law, and (2) the absence of a clear and adequate remedy at law. Cantu v. Longoria, 878 S.W. 2d. 131 (Tex. 1994); Walker v. Packer, 827 s.w. 2d 833, 839-40 (Tex. 1992). On May 3, 2016 Applicant wrote Mr. Abel Acosta, the Appeal clerk for the Court of criminal Appeals inquiring about the notification "White Card" informing Applicant that the Appeal Court received his State Application. See, exhibit C attached~ On May 11, 2016, Applicant received a letter from Mr. Abel Acosta, Appeal CLerk that after a thorough search of the Court's records, the court find that Applicant do not have a writ of Habeas Corpus filed in the Court of Criminal Appeals at this time. See, exhibit D attached. Mr. Hughey, the district clerk of Kaufman County committed fraud and misrepresentation of his Office Duty~ -4- The distirct clerk has no authority to fabricate a le~~er to applicant for the sole purpose of misleading him to •think" his State Application writ was forwarded to the Court of Criminal Appeals~ See, exhibit B; the district clerk's action is indeed &misrepresentation of Office duty and fraud. III. BRIEF IN SUPPORT A act is "ministerial" for purpose of request for writ Mandamus, if it constitute duty clearly fixed and required by law, without exercise of discretion or judgment. See, Engle v. Locker, 820 S.W~ 2d. 47 (1991); Curry v. Gray, 728 s.w. 2d. 128 (Tex. Crim. App. 1997). While it is the general rule that a mandamus will not be issue to control the action of an inferrior Court or Public Officer in a matter involving discretion. However, the writ may be issue "in a proper case" to correct a clear abuse of discretion. Crane v. Turnks, 160 Tex. 182, 328 s.w. 2d. 434, 440 (1959). The Suprem Co:u:r::t has recognized that adaption of this excep.tion is particularly important "where the remedy by way of appeal is inadequate."West v. Solitos, 563 s.w. 2d. 240, 244 (Tex. !19718). In re-iterating this standard, in Johnson v. Fourth Court of Appeals, 700 s.w. 2d. 916, 917 (Tex~ 1985). The Supreme Court stated: " •••• Mandmaus issues only to correct a clear abus~ of discretion or the violation of a duty imposed by law when there is no other adequate remedy by law. Id. at 917. ...:5- IV. ABUSE OF DISCRETION The Relator further contends the Respondent's failure to apply the law with respect to article 11.07 §3(c), ex~ plicitly enumerate that the Respondent process Relator's Habeas Corpus action within specified time limitation and forward the application top This Appeal Court. In view thereof, the Respondent has but one choice, and it is the duty prescribe by article 11.07, the failure to perform this duty constitutes a clear and prejudicial abuse of the Respondent duty fixed by 1aw. Consequently, Relator's right of access to the courts; and ~o be heard on his Habeas Corpus action; has quite stringently been impaired by the action of the Respondent~ Therefore, writ of Mandmaus will be issue when under the circumstances, law and facts permit trial court to make but one decision and it refuses to make that decision. See, Proffer v. Yates, 734 s.w. 2d~ 671,673 (Tex.Cir~ App. 1992). In Walker v. Packey, 827 s.w. 2d. 833 (Tex~ Crim. App. 1992). The Supreme Court statedi " •• ~.trial court clearly abuses its discretion, for purpose of Mandamus with the respect to resolution of factual issues or matters committed to trial court's discretion, only if trial court could rea- sonably have. reach only one decision." Id. Also see, -6- State v. Walker, 679 S.W~ 2d. 484 (Tex. Cir. 1984)("Mandamus will lie to correct an action of trial judge who commits abuse of discretion, or ~iolation of clear duty under law and when there is no other adequate remedy at law"). Ayres v. Canoles, 790 s.w. 2d. 54 (Tex. Crim. App. [990)("Writ of Mandmaus will be issue to correct trial court actions when there has been clear ·abuse of discretion particularly where remedy by law of appeal is in adequate.") v. APPEAL IS NOT AN ADEQUATE REMEDY The Relator contends that the issue of the trial court to apply the dictates of V.A.C.C~P., Article 11.07, is not an appealable issue. VI. PRAYER OF RELATOR Wherefore, premises considered the Relator, prays that this court issue an order directing the Respondent to make proposed recommendation, finding of facts and conclusion of law, and forward the same to this court within thirty (30) days. Respectfully Submitted, ~ rYI~ #t7J-.7171 Kevin Menniefee TDC No. 1727174 Ellis Unit 1697 FM 980 Huntsville, Texa~ 77343 -7- CERTIFICATE OF SERVICE I, \{e\i\o Mtoo\e..-.f.(_...L , TDC No. certifiy that a true and correct copy of the foregoing Application for Writ of Mandamus has been served by placing the same in the United STates mail on this ] day of Jvne --~~~~~---------------- ,2016, address to the District Clerk Office at: Mr.Rhonda Hughey District Clerk County Courthouse 100 w. Mulberry St". Kaufman, Texas 7514 2 Kevin S. Menniefee Pro SE Applicant \ . yo· J ~Vh.Jd r_j 2J3. lOI iP Di~1rid- ((~ondd C \u-\( Hv_ghL:t A i 00 w fYh.JI bLrr_y st K~vfrYldfl ILD.s. l5\~L . Qe·, J<:evi·Vl tvt~r1r1ietee.. J. lh<- {t.Jte. of' TLXdS' lr,~\ Cour+ 1\/0#- 2_g 7Jlo- Qb count j_ 'Dor ~hond;) Hv..9hL~ t91L:~~L find -thL fa Jlow,n!J lndrvn1Cf\+ to bL .r lc..J 1v1 ':Jour D (f,·LL i v1 +hL .:lbovL f"Ltc.rLr\LL c_~v5L V\vmbLf. fliL-:lSL h,;)VL +hi.{ \LffLf d.JiL . St:lmPid -9, \L _:)f\d Vlc·tt {y m.C of -fnL f{ ft.ifH b0 S£()J/v1!1 mL .:1 coPY of +he cl:JtL c-fJmfJ ILfiL: for my 11-r..cd{. (J Wr\ t Dt' l-\d bos CorPv5 ll. Ol t I= '~-hi bit<.;. A B _) L .;) V1d G :L l • Rr_ror+Lrs Q.r_cord volumL Y f 5 I w"J(\t io +h;:,,l)k ':Jav lVI .JJv~l'ltL for Yov ~55isf~nc[. iV\ ~\t)~-~ m~++Lr, . Cr.ct\ f,c_j md·,l {\WvlbLr. /Ol3 I liD Ooo I 011 ¥ 1 L-l ~ / : . ~-- .. ., Rhonda Hughey District Clerk County Courthouse 100 W. Mulberry St. Febrqary 2, 2016 Kaufman, Texas 75142 Kaufman County 972-932-0279 Kevin Menniefee, TDCJ # 1727174 O.B. Ellis Unit 1697 FM 980 Huntsvjlle, Texas 77343 RE: 28736C-86 EX PARTE: Kevin Menniefee Dear Mr. Menniefee: This is to acknowledge receipt of the above captioned post conviction petition for writ of habeas corpus. Article 11.07 of the Texas Code of Criminal Procedure afford the State 15 days in which it may answer. After those 15 days, the Court has 20 days in which it may order a hearing. If no order has been entered 35 days from the above date, the petition will ~e forwarded to the CoUrt of Criminal Appeals for their consideration. 1). Defendant receive~: Countl; Twenty Five (25) Years in the Texas Department of Criminal Justice Institutional Division: Fine:$0; Court Cost: $33 I .00 ; Restitution:$0 Time Credited: From 05/09/2010 to Present Count 2; Fourteen Months in the Texas Department of Criminal Justice Institutional Division, Fine: $0; Court Cost: $286.00; Restitution: $0 2) Judgment: Affirmed, April30, 2012, Memorandum Opinion: Affirmed, April30, 2012; Mandate: Mfirmeq; November 1, 2012; Memorandum qpi11ion:Affumed, hwe 21,2013, J~dgment: Jurte 21, 2013; (Dismissed) Mari.date: SeptemberJ, 2013 (Dismissed) Co'urtof Appeals Fifth District of. Texas at Dallas. · · 3). Application for Writ of Habeas Corpus Filed on 07/10/2013 (28736A-86) Writ Dismissed 4). Application for Writ of Habeas Corpus Filed on 11/7/2013) 28736B-86) Writ Denied 5). Application for Writ ofHabeas Corpus Filed on 02/02/2016) 28736C-86) ,. All further correspondence should indicate the above cause number 28736C-:S6 ~~·tt,tk~ Rhonda Hughey District Clerk -n·- ~n, RH/dw Enclosure Cc: Erliegh Norville Wiley, Criminal District Attorney Kevin Sharone Menniefee . '\ ·, •· ,f3 ' (1 Rhonda Hughey District Clerk ./ County Courthouse '~ 100 W. Mulberry St. Kaufman, Texas 75142 Kaufman County March 4, 2016 972-932-0279 Court of Criminal Appeals 12308 Capitol Station Supreme Court Building Austin, Texas 78711 ' RE: Cause No. 28736C-86 Ex Parte: Kevin Sharone Menniefee Dear Clerk, Enclosed, please find the Clerk's Record for Writ of Habeas Corpus to be filed in your Court, regarding the captioned cause number. If you have any questions, please contact our office. Sincerely, ~=y~ District Clerk Kaufman County, Texas RH/dw Cc: Erleigh Norville Wiley, . District Attorney Kevin Sharone Menniefee, Applicant Enclosure rn IA,Y ·'3) . .2.0, to RECEIVED IN COURT OF CRIMINAL APPEALS ~~~)~ P\\o~\ Ac..osia.. clerk. \ eW Court of' cc,-mi nLA.J AffJecJs 5v P\emt Covr-\ b\d-3 Z.ol w. 1 Yth s+ k!.m loft? e E.: . \Ze. Gtv~st +o Se.e l t wr\f LNdS -fowo..x-d..e~ VOl'Yt -th-e. 8lo+V1 ~\ ~-+n- L.-\ Covr\- ~ DetA-r ' A:\o.J Acosta. ~\~ 't s .;1 to(rfl:}\ \-eJte.( t\.-t~t DY1 F-e.brva._r-'J 2..l Lol IP; +h~+ CLP~\\c.:an\ -·C\~J ~is vJr\t of' t-\CNbeo...S corevs Pvrvs~nt t-o +he. T.e.:xtA.s ,Cod-e. at crim\A::>\ Proc-edure Ar~;c\-e., \\.Ol iV"'l +h.Q_ 8(a +'-7 JvJ\e--,:l\ \:)\st<\L.-Y Court. AnJ on n1a_rc..J1 '1) Zollo I re.ci-eve.d a.. VlofiG-e th:-ll+- 1--h~ wr\f \t,.-;pJ he.e 11 fow;;Jrde-J -fo Your o f!fce, 0\rtr !Iz. d"'-~5 hav--e.. e-lo.,e.r~J 51Vlc·e I hO\.v-t- hea.-rJ a/J'JJ-h,¥1!1-L ho..v-e. nof Tecie.~-e.cJ a... w~;te. card ncrhfy;n~ m-e- .Jhovt i+ hd be-en td.e,J i (') +h(. Covrf of cn mt'nu..J ttf?f?.ecvl 5. 1 ·r drfJreqv..eJtiV19 +ha.J You dJ-e.. sfa_,fl1f' .fh,-> Ieifer C)rJJ nof,-ry m-e... of +h..e. -(j I; r1!l bY s-enchn-9 m-e a., Jtd-e sfrunf'-ed J-e44e.r -hoc 1'71)' FtGO¥'"ds .. X Wdt'l+ to ~Mk Yo v i'Vl ~JvJnc-e for Yovr -A~sf~t.}~c~ 1n +his m~+er .,. D SHARON KELLER ABEL ACOSTA PRESIDING JUDGE COURT OF- CRIMINAL CLERK (512)46J.J551 LAWRENCE E. MEYERS APPEALS CHERYL JOHNSON SIAN SCHILHAB MIKE KEASLER P.O. BOX 12308, CAPITOL STATION GENERAL COLINSEL AUSTIN, TEXAS 78711 (512) 46J.J600 BARBARA P. HERVEY ELSA ALCALA BERT RICHARDSON KEVIN P. YEARY DAVID NEWELL JUDGES May 11,2016 Kevin Menniefee #1727174 Ellis Unit 1697 FM 980 Huntsville, TX 77343 RE: Your enclosed correspondence Dear Mr. Menniefee: After a thorough search of our records, we find that you do not have a Writ of Habeas Corpus filed in the Court of Criminal Appeals at this time. If you have any further questions or concerns, please direct them to the District Clerk in the convicting county where you originally filed the application. I am herewith returning your documents. AA!llg Enclosure SUPREME COURT BUILDING, 20 I WEST 14TH STREET, ROOM I 06, AUSTIN, TEXAS 7870 I WEBSITE WWW.CCA.COURTS.STATE.TX.US