Catrina Maldonado v. State
06-14-00010-CR
| Tex. App. | Jan 26, 2015Background
- Appellant Catrina Maldonado challenges the admission of photographs of a child taken two weeks after an injury; she contends the images were unduly prejudicial at the punishment phase.
- The case was decided by the Sixth Court of Appeals (Texarkana); Maldonado filed a motion for rehearing arguing appellate error.
- Maldonado argues the photographs likely provoked an irrational emotional response and could have influenced the jury toward a harsher punishment (range 5 years to 99 years or life).
- The appellate opinion relied in part on precedent from another court of appeals and concluded the photographs’ probative value outweighed their prejudicial effect.
- Maldonado contends the court failed to follow controlling Court of Criminal Appeals precedent (notably Erazo and Reese) requiring a proper Rule 403 balancing and harm analysis when graphic images are admitted.
- Relief sought: reversal of the trial court’s judgment on punishment and remand for a new punishment trial.
Issues
| Issue | Plaintiff's Argument (Maldonado) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Admissibility of post-injury photographs under Rule 403 | Photographs were unduly prejudicial, likely inflamed jury, outweighed any probative value | Photographs were probative and their probative value exceeded any prejudicial effect | Appellate court held the photographs’ probative value outweighed prejudice and were admissible |
| Whether trial court performed a proper Rule 403 balancing | Trial court did not meaningfully perform the balancing test; appellate court should not presume a proper analysis | Trial court conducted the necessary balancing and ruling was proper | Appellate court concluded the trial court performed the requisite balancing |
Key Cases Cited
- Reese v. State, 33 S.W.3d 238 (Tex. Crim. App. 2000) (discusses inadmissibility of unduly prejudicial photographs and the necessity of a balancing/harm analysis)
- Erazo v. State, 144 S.W.3d 487 (Tex. Crim. App. 2004) (addresses Rule 403 balancing for graphic evidence)
- Erazo v. State, 167 S.W.3d 889 (Tex. App. Houston 14th 2005) (appellate court’s harm analysis after erroneous admission of a photograph)