Kydrick Reshawd Benton v. State
10-14-00279-CR
| Tex. App. | Nov 9, 2016Background
- Appellant Kydrick Benton pleaded guilty to aggravated robbery; a jury assessed punishment at 38 years. Appeal followed challenging plea and suppression ruling.
- Before voir dire, the trial court advised Benton of various rights (jury trial, confront witnesses, call witnesses, not testify) but did not expressly tell him that pleading guilty would relinquish those rights or ask if plea was voluntary or if any promises induced it.
- Defense counsel noted a prior competency/sanity evaluation had been performed and that Benton had been found competent; counsel referenced addressing competency in voir dire to avoid a psychiatrist testifying.
- After pleading guilty in front of the jury, Benton later expressed during punishment that he pleaded guilty because of his conduct and wanted to accept punishment.
- Police responded to a 911 call reporting a robbery and a light-gray Mitsubishi Galant leaving the scene. Officers encountered a silver Lincoln with temporary tags whose driver fled from officers; officers later opened the vehicle, found clothing matching the robber’s description, and seized evidence without a warrant.
Issues
| Issue | Plaintiff's Argument (Benton) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1. Validity of guilty plea under Fourteenth Amendment due process | Plea was not knowingly and voluntarily entered because court did not admonish that plea relinquishes specific rights, did not ask if plea was voluntary, and no written waiver existed | Due process does not require specific admonishments; record shows Benton was informed of rights and understood them | Court: Plea was voluntary and knowing — trial court did not violate federal due process (record showed awareness of rights and later statements supported that awareness) |
| 2. Competency to plead | Trial court failed to inquire into Benton’s competency at the time of plea despite prior competency motion | Once no contemporaneous suggestion of incompetency exists and a competency exam found him competent, no further inquiry required; court had opportunity to observe Benton | Court: No due-process violation; competency had been evaluated and counsel represented he was competent, so no additional inquiry required |
| 3. Motion to suppress evidence from vehicle search (Terry/automobile) | Facts (caller said gray Mitsubishi Galant) were insufficient to justify Terry frisk/vehicle approach of a silver Lincoln; vehicle description mismatch and no plate negate reasonable suspicion | 911 call, timely proximity to scene, vehicle conduct (fleeing when officers approached), dark tint, quick discovery of matching clothing, and other facts created reasonable suspicion to detain/search | Court: Denial of suppression affirmed — officers had reasonable, articulable suspicion under the totality of circumstances to justify investigative measures and entry; discovery of clothing after door opened supported probable cause for further action |
Key Cases Cited
- Davison v. State, 405 S.W.3d 682 (Tex. Crim. App. 2013) (guilty plea must be knowing and voluntary; Boykin principles explained)
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (conviction by guilty plea unsupported by record of waiver of rights requires reversal)
- Aguirre-Mata v. State, 125 S.W.3d 473 (Tex. Crim. App. 2003) (due process does not mandate specific admonishments for plea validity)
- Medina v. California, 505 U.S. 437 (U.S. 1992) (due process requires competency to plead but court need not hold inquiry absent a suggestion of incompetency)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (officers may conduct stop/frisk based on reasonable, articulable suspicion)
- Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (911 calls have indicia of reliability that can inform reasonable suspicion analysis)
- Ford v. State, 158 S.W.3d 488 (Tex. Crim. App. 2005) (reasonable suspicion judged by totality of circumstances)