Untitled Texas Attorney General Opinion

The Attorney General of Texas F~hruary 21, 1986 JIM MAlTOX Attorney General Supreme Court BulldlnO Eonorable Dale Hanma Opinion No. JM-435 P. 0. Box 12548 Johnson County Attwmey Aus?,“, TX. 78711.2548 1st Floor, Courthouse Re: Responsibility for notlficatlon 51214752501 Cleburne , Texas 76031 of defendants In criminal cases Telex SlOI874~13B7 Telecopier 5121475-0286 Dear Mr. Hauna: 714 JacksOn. BUM 700 YOU ask the fallowing questions about notification of misdemeanor Dallas, TX. 752024508 defendants of cerl.ain criminal proceedings: 214i742.8944 1. Vhoae responsibility is it to notify 4B24 Alberta Ave., Suite 160 defendauta and/or defense attorneys of criminal El Paso. TX. 799052793 miademerluor arraignment. pre-trial, and trial 91Y533-3484 setting:, in the district court, i.e., court secretary, prosecutor, district courzerk, or 1001 Texas. Suite 700 sheriff’s office? Houston. TX. 77002.3111 71312235886 2. ‘3oea the district court have jurisdiction to order the prosecutors office to notify criminal defendants of arraignment, pre-trial, and trial 606 Broadway, Suite 312 Lubbock. TX. 79401.%79 settings? 8oBl747.523B 3. Is a prosecutor ethically prohibited by disciplinary rule DR-7-104 from notifying 4303 N. Tenth, Suite B defendants of such arraignmtnt, pre-trial. or McAllen. TX. 78501-1585 512lW2-4547 trial settings after they have employed counsel? Tour request letter poses the question primarily as a choice 200 Main Plaza, suite 400 benreen the diatl:j.ct court and the prosecutor. We note, however, that San Antonio, TX. 782062797 jurisdiction over misdemeanor cases is divfded between the district 512!225-4191 courts and the county courts according to the nature of the offense. See Code Grim. Pcoc. arts. 4.05, 4.07. In Johnson County, the county An Equal OPportUnitYl zrt and the dil,trict court have concurrent jurisdiction over certain A,,,rmati”e Action Employer misdemeanor cases. See V.T.C.S. art. 1970-335. $2. See generally, Regian v. Sowell~, 53S.W.2d 175, (Tex. Civ. App. - Waco 1976, writ ref’d n.r.e.). %rctlon 3 of article 1970-355 provides that [t]he District Clerk of Johnson County shall continu’c to perform all the clerical functions of and for the County Court of Johnson County, Insofar as all matters and csuses over which the p. 1990 Honorable Dale Hanna - Page :! (JM-435) said District Court and county Court have concurrent jurisdiction, as hereinabove set out. Consequently, we address your question solely as one between the prosecutor’s office and the court which properly has jurisdiction over the misdemeanor case in question. Article 28.01 of the Texas Code of Criminal Procedure provides for pre-trial hearings as follows: Section 1. The court may set any criminal case for a pre-trial%aring before it is set for trial upon its merits,-$d direct the defendant and his attorney, if arp of record, and the State’s attorney, to appesr before the court at the time and place statea in the court’s order for a conference and ‘Graring. The defendant rrmat be present at the arraignment, and his presence is required during any pre-trial proceeding. The pre-trial hearinS shall be to determine any of the following matters: (1) Arraignwnt of the defendant, if such be necessary; and appointment of counsel to represent the defendant, i:i such be necessary; (2) Pleadings of the defendant; (3) Special pleas, if any; (4) Excepti’>us to the form or substance of the indictment or information; (5) Motions for continuance either by the State or defenclant; provided that grounds for continuance not existing or not known at the time may be presented ,and considered at any time before the defendant announces ready for trial; (6) Motions to suppress evidence -- When a hearing on the motion to suppress evidence is granted, the ccurt may determine the merits of said motion on the motions themselves, or upon opposing affidtwits, or upon oral testimony, subject to the discretion of the court; (7) Hotionc for change of venue by the State or the defendslt; provided. however, that such motions for change of venue, if overruled at the p. 1991 Ronorable Dale Banns - Page 3 (a-435) pre-trial hearing, may be renewed by the State or the defendant during the voir dire examination of the jury; (8) Discovery; (9) Entrapment; and (10) Hotlon for appointment of interpreter. Sec. 2. When a criminal case is set for such pre-trial hearing, any such preliminary mattars not raised or filled seven days before the hearing will not thereaj’ter be allowed to be raised or filed, except by permission of the court for good cause shown; Er:3”ided that the defendant shall have sufficient notice of such hearing to allow him not less thh 10 days in which to raise or file such prelim:&ry matters. The record made at such pre-trial t;aring. the rulings of the court and the exceptions and objections thereto shall become a part of the trial record of the case upon its merits. Sec. 3. The notice mentioned in Section 2 above shall bci.f flcient if given in any one of the following wap: (1) By announcement made by the court in open court In the presence of the defendant or his attorney of recocfa; (2) By peracnal service upon the defendant or his attorney of record; (3) By mail to either the defendant or his attorney of record deposited by the clerk in the mail et least alx days prior to the date set for hearing. If the defendant has no attorney of record such notice shall be addressed to defendant at the address ,shown on his bond, if the bond shows such an a.ddress. and if not, it may be addressed to cm! of the sureties ou his bond. If the envelope wntaining the notice is properly addressed, atamlbed and mailed, the state will not be required to chow that it was received. (Emphasis added: . p. 1992 Elonorable Dale panna - Page 4 (311-435) See generallg Barbee v. Stafc, 432 S.P.2d 78 (Tax. Grim. App. 1968), cert. denied, 395 U.S. 924 ;1,969). Section 1 of article 2!),01 states that the court shall direct the defendant, his attornay, and the state’s attorney to appear at pre- triel hearings. Article Zl8.01 also authorizes three methods of notification: “[b]y announcement made by the court,” (2) “[bly personal aervicil) ” or (3) [‘bjy mail . . . deposited by the clerk.” We conclude that &is langua8e places the responsibility for notifying defendants of pre-trial hearings upon the court rather than upon the prosecuting attorney. Other provisions in tlw Code of Criminal Procedure support this conclusion and suggest that the court must also notify defendants of trial settings. Chapter 2 of the code, articles 2.01 through 2.24, sets forth the duties of magistrates , a term which includes county and district court judges. Set Code Grim. Proc. ert. 2.09. These ducira include the issuance of xi process Intended to aid In prevent1r.g end suppressing crime. Id. a:%. 2.10. Article 2.21(a) of the Code of Criminal Procedure provides3 for the general duties of court clerks as follows: Each clerk of the district or county court shall receive an3 file all papers and exhibits in respect to criminel proceedings, issue all process in such csses, and perform all other duties imposed upon then by law. In contrast, the provisions of the code vhf& set forth the dutlex of prosecutors, see arts. 2.01-2.08, neither require nor suthorize district attorneys, count]’ attorneys. or criminal district attorneys to issue or execute process. Consequently. the court, rather then the prosecutor. has the reapo~~rribility to notify defendants of pre-trial hearings and trial settings. -See Attorney General. Cpinion O-5694 (1943). Your second question requires consideretlon of whether the court holds the power to fulfil:l fta responsibility to notify defendants by ordering the prosecutor’s, office to carry out these duties of the court, a. by ordering the prosecutor’s offlce to execute process issued by the court. AE indicated. the code imposes no duty on prosecuting attorneys to uotlfy defendants of pre-trial proceediner and trial settings. See Xncan V. State, 67 S.W. 903, 905 (Tex. Civ. App. 1902, no writ); cf.‘ -- ?aulder v. Dill, 612 S.b.2d 512 ITex. Grim. App. 1980). t!oreover , the authority of the court to direct persona to serve process depends primarily on the statutes vhicb djrect the method of service. Article 2.13 of the Code of Criminal Prccrdure provides that p. 1993 Honorable Dale Banns - Pago 5 (m-435) every peace officer. as de,Eined in article 2.12. "shall execute all lawful process issued to Mm by any magistrate or court." See also Code Grim. Pro. art. 2.1(,. A prosecuting attorney is not incltided within this definition ot "peace officer." The official duty to execute service of process issued by a magistrate falls upon sheriffs. See Code Grim. Proc. arte,. 2.12, 2.13; Eeary S. Wlller Company v. -c. 452 S.W.2d 426 (Twt. 1970); Grass v. Grass. 608 S.W.2d 356 (Tax. Clv. App. - Dallas 1380, no writ); Cook v. Jones, 521 S.U.2d 335 (Tcx. Civ. App. - Dallas 1975, writ ref-'d n.r.e.); Attorney General Opinion E-595 (1975). Although the court may direct persons other than sheriffs to serve prwess in some circumstances, this authority does not properly extend t#D prosecuting attorneys. Consequently, we do not believe It is sppropriate for the court to order the prosecutor's office to notify misdemeanor defendants of pre-trial hearings and trial settings. Tour final questiorl is vhether a prosecutor is ethically prohibited from notifying misdemeanor defendants of pre-trial hearings and trial settings by DR-"-104(A) of the disciplinary rules governing the State Bar. V.T.C.S. .%rt. 320a-1, Title 14. Appendix A. art. 12, 18. Rule DR-7-104 states: (A) During the course of his representation of a client a 1awyc.r shall not: (1) Conam.nicate or cause another to com- municate on the subject of the representa- tion with'?. party he knows to be represented by 1awyc:r in that matter unless he has the prior cor,sent of the lawyer representing such other party or is authorized by law to do so. (2) Give advice to e person who is not representc:d by a lawyer, other than the advice to-secure counsel, if the interests of such person are or have a reasonable possibility of being in conflict rZth the interests of his client. (Emphasfs added). Rotifvina a defendant of the need to auuear .. in court is not a corn- munication Non the subject of the representation" prohibited by DR-7-104(A)(l). See gencEally Pannell v. State, 666 S.W.2d 96 (Tex. Grim. App. 1984); Renrlcliv. State, 694 S.W.2d 341 (Tax. Grim. App. 1985); State v. Lemon, 6011 S.W.Zd 313 (Tex. Civ. App. - Amarillo 1980, no writ). Such "advice" is more akin to advising a def&ndant to secure counsel. Conseqwntly. we believe that a proescutor is not ethically prohibited by DX-7-104 from notifying misdemeanor defendants of pre-trial hearings and trial settings. p. 1994 Ronorable Dele llama - Page 68 (JM-435) SUUMARP Article 28.01 of the Texas Code of Criminal Procedure provide:, that the court has the rrspon- sibillty to notify defendants of pre-trial hearings. The court also has the responsibility to notify defet,dants of trial settings. A prosecutor, however, is not ethically prohibited from notifying de:Eendants of pre-trial hearings and trial setting:,., J b Very truly your AA JIM MATTOX Attorney General of Texas JACK HIGRTOWER First Assistant Attorney General MARYKELLER Executive Assistant Attorneg General ROBERTGRAY Special Assistant Attorney General RICK GILPIK Chairman, Opinim Committee Prepared by Jennifer Riggs Assistant Attorney General p. 1995