Untitled Texas Attorney General Opinion

QBfficeof tfy ~ttornep QaeneraI Sbtateof Gexae DAN MORALES Al-r”RNEY GENERAL May 31.1995 Mr. Vior Rodriguez Opiion No. DM-349 Chair Texas Board of Pardons and Paroles Re: Wbetber a person wbo Ius successfully t’.O. Box 599 completed deferred adjudication ~comtnunity Huntsville, Texas 77342 SUpUViSiOll~WbOlUtSbeendiSCb8l.gCd after dismissal of charges pursuant to eection 5(c) of u-tide 42.12 of the Code of Ctiminal Procedure is eligibleto apply to the Board of Pardons end Paroles for a pardon (RQ-683) Dear Mr. Rodrigtlez: Your predecessor asked this office wbetber a person wbo has succcssftdly completed deferred adjudication comnhty supervision I&I who has been discharged atIer dimissd of charges pursuant to seotion S(c) of srticle 42.12 of the Code of Criminal F9acedure is eligiile to apply to the Board of Partixui and Paroles (the “board”) for a pardon. The board exists by virtue of article 42.18 of the Code of CriminalProcedure (the “code”) and the mandate of section 11(a) of a&e IV of the Texas Constitution. Subsection (b) of section 11 and code article 48.01 botb provide in patinent part as follows: In8llcrimindcdsqexcepttmsonandimpmcbn~the Governor shall have power, qfffrr com+fiorr, on the written signed recommendation and advice of the Board of Pardons and Paroles, or a majority thereof; to pant repiieves and commutations of punishments and pardons. . . . Tex. Const. ert. IV, 5 11(b) (emphasis added); Code Grim. Proc. ert. 48.01 (emphasis added).’ Mr. Victor Rodriguez - Page 2 (DM-349) Your predecessor explained that persons who have successfully completed deferred adjudication community supervision rue seeking full pardon9 after the dismissal of their &minsl charges pursuant to code article 42.12, section S(c). These persons apparently wish to benefit from the pardons they seek by obtaining expunction of their arrest records. See Code Grim. Proc. art. 55.02 (setting forth procedure for expunction). They would claim in a petition for expunction that they are entitled to such relief under code article 5501(a)(l)(B), which provides as follows: (a) A person who hss been arrested for commission of either a felony or misdemeanoris entitled to have all records and files relating to the mest exptmgedif: (1) the person is tried for the offense for which the person was arrested end is: .... (B) convicted and subsequentlypardoned. . . . Your predecessor asked whether the requirement of a “conviction”in the above- quoted wnsthutional and staMory pardon provisions disquahges these persons from pssdon eligibility for the reason that they have not undergone an “adjudication of guilt, id. rrt. 42.12, 0 5(c). Your predecessor explained the reason for this question in part as follows: “Since there is no conviction when charges are dismid our staff questions whether the policy of accepting applications for fidl psrdons is appropriate when there is no wnviction.” Subsections (a) to (c) of section 5 of code article 42.12 provide in part as follows (with emphasis added): (a) Except as provided by Subsection (d) of this section, when in the judge’s opinion the best interest of society and the defendant wig be served, the judge may, qtier receiving opleo of guif@or plea of nolo cmten&re, hearing tk evidence, and findig that it srrbsrenriolrsthe &femkmt ‘sguilt, defer further proceedings without entering an adjudication of guilt, and place the defendant on community supervision. . . . p. 1858 Mr. Victor Rodriguez - Page 3 (DM-349) (b) On violation of a condition of community supervision imposed under Subsection (a) of this section, the defendant may be arrested and detained as provided in Section 21 of this article. The defendant is entitled to a hearing limited to the determination by the COWIof whether it proceeds with an adjudication of guilt on the o@d charge. No appeal may be taken from this determination. After an adjudication of guilt, all proceedings, including assessment Of punishment, pronouncement of sentence, granting of community arpavision, and defendant’sappeal continue as ifthe adjudication of guilt had not been deferred. (c) &I expiration of community supervision imposed under Subsection (a) of this section, if the judge has not proceeded to adjudication of guilt, thefudse rho11Amisr the proceedings against the &fendmt anddtscharge him. , . . Weareoftheopinionthatapersonchargedwithauiminaloffbnsewhohas successlYly completed defbrred adjudication community supervision is not eligible to apply to the board for a pardon, but we believe it is unnecemary to determine whether deferred adjudication involves a “conviction” in order to reach this conclusion. If a 6ndmg of substantiated guilt under section 5(a) of code article 42.12 is not a %onviction” for purposes of the governor’s constitutional pardon power, then the govemor has no power to grant a pardon for the offense for which the defendant was found guilty because the pardon could not be granted “after conviction,”Tex. Const. art. IV, 8 1l(b). On the other hand, if a fmdhrg of substantiated guilt is a %.onviction,”then for the following reasons a subsequent dismissal of the proceeding without an “adjudication of guilt” pursuant to section S(c) would remove the matter from the governor’s pardon power. Subsection (c) continues after the above-quoted passsge to provide that, generally, “[a] dismissal and discharge under this section may not be deemed a conviction for the purposes of disqualificationsor disabilitiesimposed by law for conviction of an offenses,” but that the defendant’s prior receipt of deferred adjudication community supervision may be considered in the punishment phase of a prosecution for a subsequent offense, Code Crim. Proc. an. 42.12, $5(c)(l); see id. art. 37.07, 5 3, or in the process of determining whether to issue. renew, deny, or revoke either of the following: a license to operate a child-care facility or child-placingagency, id. art. 42.12. 0 5(c)(2); me Hum. Res. Code ch. 42, or a license or registration to provide rehabiitative mental health or medical se&es to scx offenders, Code Grim. Proc. art. 42.12, 0 5(c)(3); see V.T.C.S. art. 413(51).’ we are of the opinion that none of the provisions in subsection (c) establish penalties or d&bilities that are within the governor’s power to forgive by pardon. p. 1859 Mr. Victor Rodriguez - Page 4 (DM-349) A pardon (other than one based on a finding of actual innocence) can relieve a person only from the punishmentthst the law attaches to the commissionof a crime. Clemency power is vested in the Governor to the extent only that he can remit fmes imposed which remain unwllwted and discharge the wnvicttromtIntherpenslservice.. . . . . . . The Governor csn forgive the penalty, but he hss no power to direct that the courts shall forget either the crime or the conviction. Jones v. State, 147 S.W.Zd 508,511 (T&x.Grim. App. 1941). Any rights of citizenship that were lost as a result of the wnviction constitute a plvt of the punishment for the crime, .so the governor also may restore such rights by pardon. Miller v. State. 79 S.W. 567. 567-68 (Tar. Grim. App. 1904) (pardon restores testimonial wmpetenq); see Eprrcnooad v. Srafe, 31 S.W. 2%. 2% (Tex. Grim. App. 1895) (fill pardon restores rights of jury service and sufkage). Bkk’s Law DicHw dafkes pordm as ‘[a]n exwutivc action that mitigates M sets aside p&&nent for a crime- and “restores the rights and privileges forfeited on account of the offense.” BUM’S LAWDICTIONARY 1113 (6th cd. l!ao). (1) uponcowinionofr~to6asc,tbchcttbatthcdcfcndanthod previotlslytcwivcdconlnltity supavklollwall8 dda7cd a&ldkationof @lilt SlUUbCdlOkdbkbCfO?CthCCOWtOIjuytObCcosrridacdOllUlCiWJCOf parslty; CodeCrh F’mc.ut 42.12.05(c)@“‘~huir ddcd). p. 1860 Mr. Victor Rodrig& - Page 5 (DM-349) A pardon does not, howwer, “‘obliterate the fact of the commission of the crime and the wnviction therefor, it does not wash out the morsl stain,“’Jones, 147 S.W.Zd at 510 (quoting 46 C.J. Parulw 8 32, at 1193 (1928)); acwrdErparte Smith, 548 S.W.Zd 410,414 (Tex. Grim. App. 1977), ovemded on other ground%by Expmle Blume, 618 S.W.Zd373,376 (Tex. Grim. App. 1981), unless the pardon is based on actual immcence, see Logon v. State. 448 S.W.Zd 462, 464 (Tex. Crbn. App. 1969) (there would be no offense if pardon was based on finding of innocence). A prior conviction may be offered ,@evidence in a subsequentprosecution for the purpose of enhancementof punishment,id. at 511-12; 9ce Pensl Code 0 12.42, or to bar statutory eligiii for probation wnsideration, Watkinsv. Store. 572 S.W.Zd339,343 (Tex. Crim. App. 1973); see Code Grim. Proc. art. 42.12.0 4(e). regardless of the fict that the defendant has rewived a 111 pardon.’ Siiy, a prior conviction that has been pardoned for any reason other than hmownw is -availableto deny bail under Texas Constitution article I, section 11-A, Er purte Smith, 548 S.W.Zd at 414. or lo prove the offenses of possession of firearms by a convicted felon, Rrmo v. S&zfe,556 S.W.2d 808, 809 vex. Grim. App. 1977). and possession of burglary tools by a wnvicted felon, m v. Skafe,448 S.W.2d at 463-64. Furthermore, a felon who testifies may be subject to impeachment by proof of his conviction even ifhe has been pardoned, Sipanekv. Stute, 272 S.W. 141.142 (Tex. Crim. App. 1925); see Tex. R Crim. Evid. 6OQ.unless he shows that the pardon was gmnted on the ground of immcence or total reformation, Bennett v. State, 5 S.W. 527. 529 (Tex. App. 1887). In the absence of such a showing, a pardon “does not change the wmmon- law principle that the wnviction of an infamous offense is evidence of bad character for truth.” Id. Fiiy, a pardon will not restore the 05ce of attorney to a penon who has been disbarred because of a prior conviction or restore the good character that the person must possess to be admitted to the bar. Hankamerv. Templin, 187 S.W.Zd 549. 550 (Tex. 1945).’ The foregoing authorities show that ~apardon that is not based on a Ming of innocence may reach only the punishments,penalties, disabilities,and disqualikttions that the law would attach to the pardoned conviction. Such a pardon neitheraffects the penal wnsequences of any subsequent offenses nor restores a person’s reputation or good character. Jones, 147 S.W.Zdat 510-11. Therefore, lo the extent that the law permits the fact of a prior conviction lo be considered (1) in assessing the pensl wnsequenws of a subsequent offense or (2) in determining whether the jkrson possesses the good character requkd for licensing in a p&ion of mspwsiiity and trurt, the governor has no power to intervene by granting p. 1861 tar. vztor~octnguu - rage 6 wn-39, such a pardon. The provision in subsection (c)(l) of section 5 of article 42.12 is of the former nature; that subsection merely authorizes consideration of the prior conviction in assessing the panal wnsequences of a subsequent offense. The provisions of subsections (c)(2) 8nd (c)(3) are of the latter nature; those provisions are merely limited grants of authority to consider the fact of the defbndant’sprior guilt when that guilt is relevant to the defmdaot’s character. None of the provisions in subsection (c) constitute wntinuing penalties M disltbiities. Because nothing remainstobepardonedafkrchargesaredismissedandthe defkndant is dischsrged pumant to subsection (c). we are of the opinion that any purported pardon of an o&se issued a&r dismissaland discharge would be a nullity for lack of an object. Cj. Miller, 79 S.W. at 56768 (goveroor may extead clemency even atier sewico of sentence on felony wnviction because such wtiction continues to deprive defendant of certain civil rights we-n after expiration of sentence).” wore, a defendant who has been dischmged under subsection (c) is not eligible for consideration fbrapardon. In closing, we note that an arrest that leads to prosecutioq defked adjudication, andultimatelydismissalofchargesisnotalegaldisabii. Thefhctthatapersonhasbcen ~GSkdllUybeUlIb armssingandmaycauseproblemssuchasdifiiatltyinobtaining employment, and it may be tNe that exptmctionof the rewrd of arrest would be of great benef%totheperson. Nev&eless,anarrestisnotapunirhmentorlegaldisabiiarising &om a conviction. Article 55.01 of tbe Code of Crimbial Procedure grant, a right of arpunctionofrmstrecords~61eswhenapmonhrrbeenwnvictedudthen pardoned, but it does not empower the governor to pardon an arrests p. 1862 Mr. Victor Rodriguez - Pbge 7 (DM-349) SUMMARY A person who has successfullywmpleted deferred adjudication wmmtmity supervision and who has been discharged after dismissal of charges pursuant to section 5(c) of article 42.12 of the Code of Criminal Procedure is not eligible to apply to the Board of Psrdons and Paroles for a pardon for the crime of which the person was found guilty. for such a person has no legal dkahiities or disqualifications resulting from the deferred adjudicationthat are subject to remission by pardon. DAN MORALES Attomcy General ofTexas JORGE VEGA FiiAssiuantAttomeyGenenll SARAH J. SHIRLEY Chair, Opinion Committee p. 1863