Juan Leal, Jr. v. State

ACCEPTED 03-15-00095-CR 7392299 THIRD COURT OF APPEALS AUSTIN, TEXAS 10/15/2015 1:38:26 PM JEFFREY D. KYLE CLERK No. 03-15-00095-CR FILED IN 3rd COURT OF APPEALS In the AUSTIN, TEXAS Court of Appeals 10/15/2015 1:38:26 PM Third District JEFFREY D. KYLE Austin, Texas Clerk Juan Leal, Appellant v. The State of Texas, Appellee Appeal from the 299th District Court of Travis County Honorable Karen Sage, Judge Presiding Cause Number D-1-DC-13-300082 STATE’S BRIEF Rosemary Lehmberg District Attorney Travis County Angie Creasy Assistant District Attorney State Bar No. 24043613 P.O. Box 1748 Austin, Texas 78767 (512) 854-9400 Fax (512) 854-4810 Angie.Creasy@traviscountytx.gov AppellateTCDA@traviscountytx.gov Oral argument is not requested Table of Contents Index of Authorities............................................................................. ii Statement of Facts ................................................................................1 Summary of the State’s Argument....................................................... 2 Argument ............................................................................................. 2 Reply Point: The written judgment should not be modified. ........... 2 Prayer .................................................................................................. 3 Certificate of Compliance and Service ................................................. 4 i Index of Authorities Cases Ablon v. State, 537 S.W.2d 267 (Tex. Crim. App. 1976) ...................... 3 Dunlap v. State, No. 03-95-00743-CR, 1997 Tex. App. LEXIS 1737, 1997 WL 152628 (Tex. App.—Austin 1997, pef. ref’d) ...................... 3 Statutes Tex. Code Crim. Proc. art. 42.03 ......................................................... 3 ii No. 03-15-00095-CR In the Court of Appeals Third District Austin, Texas Juan Leal, Appellant v. The State of Texas, Appellee Appeal from the 299th District Court of Travis County Honorable Karen Sage, Judge Presiding Cause Number D-1-DC-13-300082 STATE’S BRIEF To the Honorable Third Court of Appeals: Now comes the State of Texas and files this brief in response to Appellant’s brief. Statement of Facts Appellant was placed on deferred adjudication for assault. The State filed a 3-page motion to adjudicate, alleging numerous violations. CR 50-52. After a hearing, the judge stated on the record 1 that she found the allegations in the motion to be true. The judge then proceeded to read through the allegations one-by-one. 2RR 150-52. As she was reading through the lengthy list, the judge missed a few allegations. Appellant asks this court to modify the written judgment to delete the allegations that were not read aloud by the judge. CR 70-72. Summary of the State’s Argument There is no real conflict between the oral pronouncement and the written judgment. Even if there were, the trial court’s written order revoking probation controls over the oral pronouncement. Therefore, the written judgment should not be modified. Argument Reply Point: The written judgment should not be modified. As an initial matter, the judgment is not actually in conflict with the oral pronouncement because the judge did not find that any of the allegations were Not True. To the contrary, she stated that the allegations were True. She just missed a few when she read them aloud. 2 Even if there was a discrepancy, the trial court’s written order revoking probation controls over the oral pronouncement. See Dunlap v. State, No. 03-95-00743-CR, 1997 Tex. App. LEXIS 1737, *5-7, 1997 WL 152628 (Tex. App.—Austin 1997, pef. ref’d) (not designated for publication), citing Ablon v. State, 537 S.W.2d 267, 268-69 (Tex. Crim. App. 1976). Therefore, the written judgment should not be modified. Appellant argues that the oral pronouncement should control, but the cases he cites involve discrepancies as to the sentence assessed. In that situation, the oral pronouncement controls because the sentence must be pronounced in the defendant’s presence. See Tex. Code Crim. Proc. art. 42.03, §1(a). But there is no discrepancy as to the sentence assessed in this case. Rather, the discrepancy, if any, involves the grounds for revocation. In that situation, the written judgment controls. Prayer The State asks this Court to overrule Appellant’s point of error and affirm the trial court’s judgment. 3 Respectfully submitted, Rosemary Lehmberg District Attorney Travis County Angie Creasy Assistant District Attorney State Bar No. 24043613 P.O. Box 1748 Austin, Texas 78767 (512) 854-9400 Fax (512) 854-4810 Angie.Creasy@traviscountytx.gov AppellateTCDA@traviscountytx.gov Certificate of Compliance and Service I certify that this brief contains 383 words. I further certify that, on the 15th day of October, 2015, a true and correct copy of this brief was served, by U.S. mail, electronic mail, facsimile, or electronically through the electronic filing manager, to the defendant’s attorney, Paul Evans, 811 Nueces Street, Austin, Texas 78701. Angie Creasy 4