Mitchell Hollis Wright v. State

ACCEPTED 03-14-00469-CR 6448351 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/11/2015 3:07:47 PM JEFFREY D. KYLE CLERK CAUSE NO. 03-14-00469-CR FILED IN 3rd COURT OF APPEALS _________________________________________________ AUSTIN, TEXAS 8/11/2015 3:07:47 PM IN THE COURT OF APPEALS JEFFREY D. KYLE FOR THE THIRD DISTRICT OF TEXAS Clerk AUSTIN DIVISION _________________________________________________ MITCHELL HOLLIS WRIGHT § § v. § § STATE OF TEXAS § _______________________________________________ APPELLANT’S MOTION FOR REHEARING _______________________________________________ Justin Bradford Smith Texas Bar No. 24072348 Harrell, Stoebner, & Russell, P.C. 2106 Bird Creek Drive Temple, Texas 76502 Phone: (254) 771-1855 FAX: (254) 771-2082 Email: justin@templelawoffice.com ATTORNEY FOR APPELLANT Appellant’s Motion for Rehearing Page 1 Wright v. State; Cause No. 03-14-00469-CR TO THE HONORABLE COURT OF APPEALS: COMES NOW, Appellant MITCHELL HOLLIS WRIGHT, who files this Motion for Rehearing, and respectfully asks this Court to revise its judgment in Cause Number 03-14-00469-CR only. I. 1. On July 28, 2015, this Court issued an opinion sustaining Appellant’s three issues. The first two issues complained that restitution and its accompanying fee should not have been ordered against Appellant in Trial Court Cause Number 23,385 (Appellate Cause Number 03-14-00469). 2. The Court agreed, and in its opinion “modif[ied] the trial court’s judgment adjudicating guilt in cause number CR 23,285 to delete the language regarding the payment of restitution.” Wright v. State, 03-14-00469-CR, 2015 WL 4609743, at *3 (Tex. App.—Austin July 28, 2015, no. pet. h.). The Court further “modif[ied] the court costs in the judgment adjudicating guilt in cause number CR23,385 to delete the $12.00 restitution fee.” Id. 3. However, the Court’s judgment in Cause No. 03-14-00469-CR (Trial Court Cause Number CR 23,385) modifies the trial court’s judgment only to reflect the correct offense (as requested in Appellant’s third issue), but does not modify the judgment to delete the restitution and the restitution fee. Appellant’s Motion for Rehearing Page 2 Wright v. State; Cause No. 03-14-00469-CR 4. Accordingly, Appellant asks this Court to grant this motion for rehearing and issue a new judgment in Cause No. 03-14-00469-CR that also modifies the trial court’s judgment to delete the restitution and the restitution fee, as ordered in the Court’s opinion. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant asks this Court to grant his Motion for Rehearing and issue a corrected judgment in Cause No. 03- 14-00469-CR that deletes the restitution and the restitution fee in the trial court’s judgment in Cause No. CR 23,385, and which still modifies the judgment to reflect the correct statute for the offense. Respectfully submitted: /s/ Justin Bradford Smith Justin Bradford Smith Texas Bar No. 24072348 Harrell, Stoebner, & Russell, P.C. 2106 Bird Creek Drive Temple, Texas 76502 Phone: (254) 771-1855 FAX: (254) 771-2082 Email: justin@templelawoffice.com ATTORNEY FOR APPELLANT Appellant’s Motion for Rehearing Page 3 Wright v. State; Cause No. 03-14-00469-CR CERTIFICATE OF COMPLIANCE I hereby certify that, pursuant to Rule 9.4(i)(D) of the Texas Rules of Appellate Procedure, Appellant’s Motion for Rehearing contains 288 words. /s/ Justin Bradford Smith Justin Bradford Smith CERTIFICATE OF SERVICE I hereby certify that, on August 11, 2015, a true and correct copy of the Appellant’s Motion for Rehearing was sent to the following counsel by eservice: W.W. Torrey Joseph P. Johnson Milam County District Attorney’s Office 204 N. Central Cameron, Texas 76520 Email: daoffice@milamcounty.net Attorneys for the State /s/ Justin Bradford Smith Justin Bradford Smith Appellant’s Motion for Rehearing Page 4 Wright v. State; Cause No. 03-14-00469-CR