Enrique Gonzalo Euan v. State, 05-16-00252-CR

Enrique Gonzalo Euan pleaded open guilty to aggravated sexual assault of a child and was sentenced to 12 years’ imprisonment. The plea was based on a written judicial confession admitted without objection.
At plea/sentencing hearings, Euan acknowledged understanding the charges, range of punishment, waiving a jury, and having reviewed paperwork and admonishments with counsel.
Defense evidence: psychotherapist testified Euan had alcohol-related blackouts, depression history, and limited recollection of the offense but likely committed it; family members corroborated heavy drinking and memory gaps.
Euan testified he could not remember penetrating the child due to intoxication but also stated on multiple occasions, "I did it," and confirmed signing a judicial confession.
Trial court found Euan competent, accepted the plea as knowingly and voluntarily made, and later denied any request to withdraw the plea.

Issue	Appellant's Argument	State's Argument	Held
Trial court failed to elicit plea in open court (Art. 27.13)	Trial court never obtained an oral plea in open court as required	Issue waived for failure to object; alternatively, substantial compliance occurred	Waived for appeal; assuming review, court found substantial compliance with Art. 27.13
Trial court abused discretion by not sua sponte holding competency hearing	Testimony about alcohol blackouts and memory loss raised legitimate competency concerns	No evidence of present inability to consult with counsel or understand proceedings; trial court properly declined inquiry	No abuse of discretion; evidence did not trigger a competency inquiry
Insufficient evidence to support conviction under Art. 1.15	Appellant argued insufficiency due to his denial at plea hearing	Judicial confession and stipulation satisfy Art. 1.15; evidence need not be proved beyond reasonable doubt	Article 1.15 is systemic (not waived); judicial confession embraced elements and was sufficient
Whether amnesia/intoxication can establish incompetence	Amnesia from intoxication rendered plea involuntary/incompetent	Intoxication/amnesia at time of offense is not proof of present incompetence; only extraordinary amnesia undermining rationality could	Reversed: intoxication-related memory loss did not show present incompetence; competency finding upheld

Costilla v. State, 146 S.W.3d 213 (Tex. Crim. App. 2004) (Art. 27.13 substantial‑compliance discussion)
Morris v. State, 301 S.W.3d 281 (Tex. Crim. App. 2009) (prosecution while incompetent violates due process)
Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (Art. 46B procedures for competency determinations)
Gonzales v. State, 313 S.W.3d 840 (Tex. Crim. App. 2010) (amnesia generally not incompetence absent extraordinary impairment)
Menefee v. State, 287 S.W.3d 9 (Tex. Crim. App. 2009) (judicial confession can satisfy article 1.15)
Ex parte Williams, 703 S.W.2d 674 (Tex. Crim. App. 1986) (historic discussion of article 1.15 and evidentiary safeguard)
Boykin v. Alabama, 395 U.S. 238 (1969) (effect of guilty plea on trial rights)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence)