Meadows v. State
455 S.W.3d 166
| Tex. Crim. App. | 2015Background
- Appellant (Meadows) was convicted by a jury of two counts of aggravated robbery and sentenced to 75 years on each count; the court of appeals affirmed.
- At trial the State sought to impeach Meadows on cross-examination with several prior convictions, some more than ten years old, and an intervening 2009 assault-family-violence conviction.
- The trial court allowed questioning about remote convictions, finding their probative value, supported by specific facts, outweighed prejudice and noting Meadows had ‘‘opened the door’’ regarding harming others.
- On direct appeal Meadows argued the trial court abused its discretion by admitting convictions older than ten years under the common‑law "tacking" doctrine instead of applying Tex. R. Evid. 609(b).
- The court of appeals applied the less stringent Rule 609(a) balancing test ("outweighs") and the tacking doctrine to uphold admission.
- The Texas Court of Criminal Appeals granted review to decide whether Rule 609(b)’s plain language supersedes the common‑law tacking doctrine and whether the court of appeals used the correct standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the common‑law tacking doctrine survives Rule 609 | Tacking is inconsistent with Rule 609(b); remote convictions must be judged under Rule 609(b)’s "substantially outweighs" test | State conceded Rule 609(b) governs remoteness but argued result would be the same under 609(b) | Rule 609’s plain text supplants the tacking doctrine; tacking no longer permitted |
| Proper standard for admitting convictions >10 years old | Trial court and court of appeals should have applied Rule 609(b) (probative value must "substantially outweigh" prejudice) | Court of appeals used Rule 609(a) (probative value need only "outweigh" prejudice) but insists outcome would stand under 609(b) | The court of appeals erred by using 609(a); remand for reconsideration under Rule 609(b) |
| Whether intervening convictions can be considered in the 609(b) analysis | Intervening convictions may be relevant to dilute prejudice but cannot convert remoteness into recency | Intervening convictions are a relevant specific fact under Rule 609(b) | Intervening convictions are relevant specific facts a court may consider under Rule 609(b) but cannot be used to "tack" to avoid the ten‑year rule |
| Whether the trial court abused its discretion admitting the remote convictions | Admission was improper under the correct 609(b) standard (appellant) | Admission proper even under 609(b) given facts (State) | Court did not resolve abuse-of-discretion on merits; remanded to court of appeals to apply 609(b) standard and reassess admission |
Key Cases Cited
- McClendon v. State, 509 S.W.2d 851 (Tex. Crim. App. 1974) (discusses remoteness of prior convictions and case‑by‑case approach)
- Crisp v. State, 470 S.W.2d 58 (Tex. Crim. App. 1971) (intervening conduct relevant to remoteness inquiry)
- Ex parte Menchaca, 854 S.W.2d 128 (Tex. Crim. App. 1993) (admissibility of prior convictions governed by Rule 609)
- Bruton v. State, 428 S.W.3d 865 (Tex. Crim. App. 2014) (principles of construing court rules; effectuate plain language)
- Leyba v. State, 416 S.W.3d 563 (Tex. App.—Houston [14th Dist.] 2013) (holding Rule 609 supplants common‑law tacking)