Menefield v. State
343 S.W.3d 553
| Tex. App. | 2011Background
- Menefield was convicted of possessing a controlled substance in an amount less than one gram.
- He appeals claiming ineffective assistance of trial counsel.
- Primary claim: counsel failed to object to admission of the laboratory report showing trace cocaine in a pipe.
- The report was sponsored by the DPS lab manager and prepared by a former supervisor; no independent analysis by Conrad was presented.
- Defense did not object to the report; the court admitted it as a business record.
- Court reversed and remanded for a new trial due to Confrontation Clause violation and ineffective assistance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel's failure to object to the lab report violated the Confrontation Clause. | Menefield argues counsel was ineffective for not objecting. | State contends no clear strategy shown; silent object may be strategic. | Yes; admission violated Confrontation Clause and counsel was ineffective. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes ineffective assistance standard and prejudice requirement)
- Cannon v. State, 252 S.W.3d 342 (Tex.Crim.App.2008) (presumes legitimate trial strategy; burden to rebut)
- Mata v. State, 226 S.W.3d 425 (Tex.Crim.App.2007) (presumption of legitimate strategy; record must show reasons)
- Ex parte Niswanger, 335 S.W.3d 611 (Tex.Crim.App.2011) (evidence of reasons for conduct not required when no reasonable strategy)
- Andrews v. State, 159 S.W.3d 98 (Tex.Crim.App.2005) (no reasonable trial strategy justifying silence when evidence is inadmissible)
- Crawford v. Washington, 541 U.S. 36 (U.S. Supreme Court 2004) (Confrontation Clause excludes testimonial out-of-court statements)
- Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527 (U.S. Supreme Court 2009) (laboratory reports as testimonial statements under Confrontation Clause)
- Cuadros-Fernandez v. State, 316 S.W.3d 645 (Tex.App.-Dallas 2009) (applies Confrontation Clause to lab reports)
- Hamilton v. State, 300 S.W.3d 14 (Tex.App.-San Antonio 2009) (confrontation analysis in lab-report evidence)