Francisco Javier Iniquez v. State
2012 Tex. App. LEXIS 5436
| Tex. App. | 2012Background
- Appellant Francisco Iniquez was convicted by jury of aggravated assault and sentenced to 15 years’ imprisonment in the Texas Court of Appeals, Third District, Austin.
- Prior to trial, Iniquez moved for psychological examinations; the court granted two exams resulting in two separate competency opinions.
- Dr. Richard Coons (psychiatrist) and Dr. Dusty Humes (clinical psychologist) both opined that Iniquez was competent to stand trial.
- During trial, Iniquez sought to have Dr. Humes testify that his mental defects prevented forming the mens rea for assault; the court excluded the testimony as irrelevant/misleading.
- The court conducted a sua sponte competency review and concluded there was no bona fide doubt about Iniquez’s competency, and did not hold a competency hearing.
- On appeal, Iniquez argues (1) failure to sua sponte conduct a competency hearing and (2) exclusion of Dr. Humes’s testimony; the court affirms the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by not sua sponte conducting a competency hearing | Iniquez argues amnesia and behavior created bona fide doubt | State contends no bona fide doubt; examinations showed competency | No error; trial court did not abuse discretion. |
| Whether excluding Dr. Humes’s testimony on mens rea was an error | Humes could show lack of mens rea due to mental defects | Testimony irrelevant or misleading about mens rea | No abuse of discretion; testimony excluded as irrelevant/misleading. |
Key Cases Cited
- Morris v. State, 301 S.W.3d 281 (Tex. Crim. App. 2009) (amnesia alone does not automatically raise competency doubt unless rational thinking is affected)
- Montoya v. State, 291 S.W.3d 420 (Tex. Crim. App. 2009) (bona fide doubt standard for competency inquiry/hearing)
- Moore v. State, 999 S.W.2d 385 (Tex. Crim. App. 1999) (bona fide doubt requires potential inability to consult or understand proceedings)
- Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (mental defect may affect mens rea; still guilty if intent to shoot person)
- Jackson v. State, 548 S.W.2d 685 (Tex. Crim. App. 1977) (amnesia/diminished memory not per se incompetency)
- McDaniel v. State, 98 S.W.3d 704 (Tex. Crim. App. 2009) (due process requires competency determination when evidence raises doubt)