Charles Anthony Lherault v. State
04-15-00018-CR
| Tex. App. | May 7, 2015Background
- Appellant Charles Anthony Lherault was convicted of family assault by choking and continuous family violence after a jury trial; he was sentenced to 26 and 10 years.
- Before the merits trial a jury in a competency hearing found Lherault competent to stand trial; this appeal challenges that finding.
- Defense evidence: forensic psychologist Dr. Jack Ferrell testified Lherault understood charges but was unable to consult with counsel rationally due to fixation, mistrust of counsel, and distractibility; Lherault testified he distrusted his lawyer and relied on a nonlawyer adviser.
- State evidence: psychiatrist Dr. Brian Skop testified Lherault understood the charges, consequences, and legal process and was competent despite narcissistic traits and frustration with counsel.
- The competency dispute centered on Art. 46B.003 standards (ability to consult with counsel with a reasonable degree of rational understanding and rational/factual understanding of proceedings).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Lherault) | Held |
|---|---|---|---|
| Whether the jury’s finding that Lherault was competent to stand trial is against the great weight and preponderance of the evidence | Skop/State: Lherault understood charges, consequences, and legal roles; despite personality traits he had capacity to consult and assist counsel | Ferrell/Defendant: Lherault’s fixed preoccupations, mistrust of counsel, and inability to engage in reasoned choice rendered him unable to consult with counsel rationally and thus incompetent | Jury found competent; appellant argues this finding is against the great weight of evidence and seeks reversal |
Key Cases Cited
- Morris v. State, 301 S.W.3d 281 (Tex. Crim. App. 2009) (defines competency standards and evidentiary factors)
- Meraz v. State, 785 S.W.2d 146 (Tex. Crim. App. 1990) (standard for reversing competency findings under great-weight review)
- Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (both prongs of competency requirement and due process implications)
- Moon v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014) (appellate review may include factual sufficiency where preponderance standard applied)
- Brooks v. State, 323 S.W.3d 823 (Tex. Crim. App. 2010) (discusses standards relevant to appellate review of factual sufficiency)
- Cooper v. Oklahoma, 517 U.S. 348 (U.S. 1996) (due process prohibits criminal trial of incompetent defendants)