Mathew Mungia v. the State of Texas, 13-20-00493-CR

Mungia was indicted for possession with intent to deliver a controlled substance (penalty group 2/2A), between 4g and 400g. He pleaded guilty pursuant to a plea agreement.
Trial court deferred adjudication and placed Mungia on five years community supervision on December 18, 2019.
State moved to revoke (filed March 2, 2020), alleging manufacture/delivery of synthetic marijuana on January 7, 2020, and that Mungia admitted daily synthetic-marijuana use. Mungia pleaded true to both allegations; State dismissed the charged January 7 offense in exchange for the pleas.
At the revocation hearing Mungia stated he is a special-needs individual who needs dialysis; counsel said an intermediate sanction facility (ISF) would not be suitable. Mungia requested placement in TDCJ’s medical unit as time served.
The court revoked community supervision, adjudicated guilt on the original indictment, and sentenced Mungia to ten years’ imprisonment with direction to place him in the medical unit. Mungia appealed, arguing the sentence violated the Eighth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 10-year sentence is cruel and unusual / disproportional under the Eighth Amendment	Mungia: sentence is excessive due to his special-needs status, dialysis requirement, and severe synthetic-marijuana addiction; ISF should have been an option	State: Mungia forfeited the claim by failing to object in trial court; sentence is within statutory range and record lacks evidence for a proportionality analysis	Court: Overruled — complaint not preserved; sentence within statutory range and not shown to be grossly disproportionate

Jackson v. State, 680 S.W.2d 809 (Tex. Crim. App. 1984) (standard: appellate review of punishment is for abuse of discretion)
State v. Simpson, 488 S.W.3d 318 (Tex. Crim. App. 2016) (successful proportionality claims require gross disproportionality; relief is rare)
Harmelin v. Michigan, 501 U.S. 957 (U.S. 1991) (Eighth Amendment proportionality principles do not require strict proportionality)
Lockyer v. Andrade, 538 U.S. 63 (U.S. 2003) (reinforces high bar for disproportionality challenges)
Trevino v. State, 174 S.W.3d 925 (Tex. App.—Corpus Christi–Edinburg 2005) (failure to object at trial forfeits proportionality complaint on appeal)
Smith v. State, 721 S.W.2d 844 (Tex. Crim. App. 1986) (preservation rule: timely, specific objection required to preserve sentencing complaints)
Ex parte Chavez, 213 S.W.3d 320 (Tex. Crim. App. 2006) (punishment within legislatively prescribed range is generally unassailable on appeal)
Solem v. Helm, 463 U.S. 277 (U.S. 1983) (comparative-sentencing analysis can be relevant to disproportionality claims)