Juan Jose Ramirez, Sr. v. State, 03-15-00727-CR

Appellant Juan Jose Ramirez, Sr. was indicted for aggravated assault with a deadly weapon and proceeded to a jury trial where he was convicted and sentenced to 10 years' imprisonment.
Before trial, the court held a short Plea Bargain Deadline hearing during which the court explained the range of punishment and the State recited a plea offer; Ramirez declined the offer at that hearing.
Ramirez did not request a court‑appointed licensed Spanish interpreter at the Plea Bargain Deadline hearing; his trial counsel (who spoke Spanish) interpreted during that hearing.
At trial two certified Spanish/English interpreters were present: one interpreted for Ramirez and the other for witnesses; interpretation occurred during trial proceedings.
Appellant appealed, arguing the trial court was obligated to provide a licensed court interpreter for the Plea Bargain Deadline hearing and that the absence of one violated his rights and was preserved for appellate review.

Issue	Plaintiff's Argument (Appellant)	Defendant's Argument (State)	Held
Whether failing to provide a licensed court interpreter at the Plea Bargain Deadline hearing requires reversal	Ramirez: court was obligated to appoint a licensed interpreter; absence violated his rights	State: Ramirez waived the right by not requesting an interpreter and demonstrated sufficient understanding via counsel's interpretation and his own responses	Court affirms that failure to request an interpreter waives appellate complaint absent record showing inability to understand; issue not preserved

Baltierra v. State, 586 S.W.2d 553 (Tex. Crim. App. 1979) (trial court must provide interpreter when defendant cannot understand English to protect confrontation rights)
Garcia v. State, 149 S.W.3d 135 (Tex. Crim. App. 2004) (defendant's inability to understand English can vitiate waiver of rights where interpreter did not interpret other witnesses)
Ex parte Marez, 464 S.W.2d 866 (Tex. Crim. App. 1971) (statutory purpose of interpreter appointment tied to right of confrontation; protection triggered by request or court awareness)
Briones v. State, 595 S.W.2d 546 (Tex. Crim. App. 1980) (waiver principles for constitutional rights)
Ex parte Zantos-Cuebas, 429 S.W.3d 83 (Tex. App.—Houston [1st Dist.] 2014) (waiver of rights requires awareness; informal/unqualified interpreters can undermine validity of plea where critical admonitions were not translated)
Hernandez v. State, 986 S.W.2d 817 (Tex. App.—Austin 1999, pet. ref’d) (failure to request interpreter waives complaint absent record showing defendant could not understand proceedings)