Daniel Vadnais v. State
03-14-00578-CR
| Tex. App. | Aug 19, 2015Background
- Appellant Daniel Vadnais was indicted for fraudulent use or possession of identifying information (10–50 items) in 2013 stemming from a same-transaction misdemeanor theft arrest in 2012.
- Capias issued Aug 14, 2013; executed Feb 4, 2014 while Vadnais serving time for an unrelated offense.
- Two pretrial hearings led to resets as plea negotiations continued.
- On Aug 11, 2014, the trial court denied a speedy-trial dismissal motion; on Aug 13, 2015 a jury found Vadnais guilty and imposed a 10-year sentence.
- Vadnais appealed challenging: speedy-trial denial, 404(b) extraneous-offense evidence, Rule 403 prejudice, and sufficiency of the evidence.
- State Energy: the State’s brief argues the trial court properly denied the speedy-trial motion, Vadnais waived 404(b) objection, any error was harmless with a limiting instruction and strong guilt evidence, and the evidence was legally sufficient to support the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Vadnais’s speedy-trial denial proper under Barker factors? | Vadnais contends delay exceeded Barker thresholds | State argues delay justified; no prejudice shown | Speedy-trial denial affirmed; delay justified; no reversible error |
| Did Vadnais waive his 404(b) objection by stipulating to admissibility? | Vadnais did object initially but later stipulated | Stipulation constitutes waiver of 404(b) objection | Waiver; error, if any, harmless given limiting instruction and guilt evidence |
| Did the 404(b) admission create reversible error given limiting instruction and overwhelming evidence? | Admission prejudicial despite instruction | Limiting instruction mitigated prejudice; overwhelming evidence of guilt | Not reversible error; admission harmless |
| Was the Rule 403 objection properly preserved and did admission cause substantial harm? | Appellant preserved objection; 403 error | No preserved 403 error or harm; harmless | Error not preserved; or harmless if preserved; no reversible harm |
| Was there sufficient evidence to convict on more than 10 items of identifying information? | State proved at least 13 items; intent shown | Evidence insufficient in some aspects | Sufficient evidence to sustain conviction |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (four Barker factors govern speedy-trial analysis)
- Gonzales v. State, 435 S.W.3d 801 (Tex. Crim. App. 2014) (speedy-trial protections; excessive delays may presumptively compromise reliability)
- Munoz v. State, 991 S.W.2d 818 (Tex. Crim. App. 1999) (applies Barker factors; delay attributable to defendant may waive rights)
- Dragoo v. State, 96 S.W.3d 308 (Tex. Crim. App. 2003) (timely assertion of right; persistence affects strength of claim)
- Cantu v. State, 253 S.W.3d 273 (Tex. Crim. App. 2008) (one-year delays trigger Barker review; prejudice not shown here)