Mauricio Rodriguez Celis v. State, 354 S.W.3d 7

Celis was convicted of 14 counts of falsely holding himself out as a lawyer under Tex. Penal Code § 38.122(a).
Indictments covered two dockets: 07-CR-4046-E (seven counts) and 08-CR-1365-E (sixteen counts).
Evidence showed Celis operated CGT Law Group International, LLP in Nueces County, Texas, without Texas licensure and without a Texas cedula; he claimed to be a lawyer in Mexico.
The State presented 20 witnesses and many exhibits; Celis relied on similar witnesses and added three witnesses in his defense.
After trial, Celis moved to recuse Judge Luitjen for bias; affidavits from jurors supported the motion, leading to successive recusals and new-trial proceedings which the trial court denied; the appeals court ultimately affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Celis argues the evidence fails to show he was not licensed in another state.	Celis contends lack of licensure in any state negates the offense.	Evidence sufficient; convictions affirmed.
Judicial bias and new-trial denial	Celis claims Judge Luitjen was biased, warranting a new trial.	State contends no bias established; record insufficient for reversal.	Motion for new trial denied; no reversible bias established.
Constitutionality: vagueness/overbreadth of § 38.122	Section 38.122 is vague and overbroad, infringing First Amendment rights as applied.	Statute narrowly regulates commercial speech and is not overbroad or vague.	Statute not facially overbroad or vague; applied challenges rejected.
Jury charge—mental state and mistake of fact	Requested charges on intent and mistake of fact were necessary to negate culpability.	Court's charge tracked the statute and indictments; no extra instruction required.	Charge proper; no reversible error; issues rejected.
Evidentiary rulings	Exclusion of Tamaulipas letter and hearsay objections were prejudicial.	Rulings were within discretion and not reversible error.	Rulings within discretion; any error non-prejudicial; issues rejected.

Satterwhite v. State, 979 S.W.2d 626 (Tex. Crim. App. 1998) (evidence sufficient even when defendant licensed elsewhere; good standing issues discussed)
Liteky v. United States, 510 U.S. 540 (U.S. 1994) (judicial statements during trial must show deep-seated favoritism or antagonism)
Sandoval v. State, 842 S.W.2d 782 (Tex. App.—Corpus Christi 1992) (no additional mental state required beyond statute’s specific intent)
O'Quinn v. State Bar of Texas, 763 S.W.2d 397 (Tex. 1988) (regulation of out-of-state lawyers; related to good standing concept)
Sperry v. Florida, 373 U.S. 379 (U.S. 1963) (state interest in regulating the practice of law)