Christopher Rios v. State
377 S.W.3d 131
Tex. App.2012Background
- Rios pleaded guilty to a class B misdemeanor driving while intoxicated under a plea bargain.
- Initial sentencing: 180 days’ confinement and $200 fine, suspended; Rios placed on one year of community supervision with sobriety-related conditions.
- State later moved to revoke community supervision; trial court resentenced Rios to 120 days’ confinement.
- Breath test results showed BAC around 0.149–0.161; later discovered intoxilyzer technician falsified calibration records, rendering the test invalid.
- Rios sought habeas relief arguing the plea was involuntary because it was based on invalid breath-test results.
- A stipulation at habeas hearing acknowledged the breath test was invalid and that the case could be vacated and dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the plea involuntary due to reliance on invalid breath tests? | Rios contends the plea was induced by falsified intoxilyzer results. | Rios argues the State’s misrepresented evidence rendered the plea involuntary. | Yes; plea was involuntary due to State’s invalid breath-test evidence. |
| Did the trial court abuse its discretion in denying habeas relief given the stipulation and evidence? | Rios asserts the court abused discretion by denying relief despite the stipulation and credibility issues. | State contends the trial court properly weighed credibility and evidence. | Yes; the trial court abused its discretion and habeas relief was proper. |
Key Cases Cited
- Kniatt v. State, 206 S.W.3d 657 (Tex.Crim.App. 2006) (plea voluntariness requires due process; prima facie validity with admonitions)
- Ex parte White, 160 S.W.3d 46 (Tex.Crim.App. 2004) (deference to trial court findings in habeas proceedings)
- Ex parte Brtseno, 135 S.W.3d 1 (Tex.Crim.App. 2004) (credibility reweighing in habeas review)
- Brady v. United States, 373 U.S. 83 (U.S. 1963) (due process violation for suppression of favorable evidence)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (prosecution kule to disclose favorable evidence; Brady obligation)
- Ex parte Chabot, 300 S.W.3d 768 (Tex.Crim.App. 2009) (perjured testimony violates due process when used to convict)
- Salazar v. State, 38 S.W.3d 141 (Tex.Crim.App. 2001) (habeas relief appropriate where falsified evidence taints conviction)
- Ex parte Lewis, 587 S.W.2d 701 (Tex.Crim.App. 1979) (failure to disclose favorable information before plea affects voluntariness)