Moises Renteria v. State
06-15-00106-CR
| Tex. App. | Dec 30, 2015Background
- Moises Renteria was charged with aggravated sexual assault and indecency with a child after DNA showed he fathered the victim's child; he was later convicted after a bench trial and sentenced to life and 20 years (concurrent).
- Renteria did not speak English; proceedings used an interpreter and translation of his statements appears throughout the record.
- The trial court extensively questioned Renteria about whether he wanted a jury trial; Renteria expressed confusion about signing a written waiver but repeatedly indicated he preferred a trial to the judge rather than a jury.
- The court sua sponte ordered a psychological competency examination after hearing the defendant's statements and letter; the court-appointed psychologist found Renteria competent to stand trial.
- A written jury-trial waiver was executed in court with counsel, the State, and the trial judge present; no formal competency hearing was held after the psychologist's report.
- Renteria appealed, arguing (1) the jury waiver was not knowing, intelligent, and voluntary, and (2) the trial court erred by not holding a formal competency hearing after ordering evaluation.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Renteria) | Held |
|---|---|---|---|
| Validity of jury-trial waiver | Waiver was valid: defendant understood difference and knowingly chose bench trial; executed written waiver per statute | Waiver was not knowing, intelligent, voluntary; confusion/translations show he didn’t understand requirement to sign or consequences | Court held waiver was valid: record supports voluntary, knowing waiver and signing complied with law |
| Necessity of formal competency hearing after examination | No hearing required where court ordered exam sua sponte, examiner found defendant competent, and record showed no bona fide doubt | Once court ordered exam, a competency hearing was required because defendant’s statements showed bona fide doubt | Court held no error: psychologist found competency; record did not raise bona fide doubt requiring a formal hearing |
Key Cases Cited
- Guillett v. State, 677 S.W.2d 46 (Tex. Crim. App. 1984) (State must establish an express, knowing, intelligent waiver of jury trial in the record)
- McDaniel v. State, 98 S.W.3d 704 (Tex. Crim. App. 2003) (threshold for bona fide doubt about competency requires evidence of recent severe mental illness, moderate retardation, or truly bizarre acts)
- Moore v. State, 999 S.W.2d 385 (Tex. Crim. App. 1999) (ordering an examination does not automatically require a competency hearing where record supports no bona fide doubt)
- Carpenter v. State, 507 S.W.2d 794 (Tex. Crim. App. 1974) (error to fail to submit competency to jury when court clearly found competency issue existed)
- Ex parte Hagans, 558 S.W.2d 457 (Tex. Crim. App. 1977) (substantial evidence raising bona fide doubt requires procedural protections)
- Townsend v. State, 427 S.W.2d 55 (Tex. Crim. App. 1968) (psychiatrist’s finding of present insanity requires competency submission)
- Fuller v. State, 253 S.W.3d 220 (Tex. Crim. App. 2008) (no bona fide doubt when evidence insufficient; no evaluation required)
- Pate v. Robinson, 383 U.S. 375 (U.S. 1966) (recognition of due-process requirement to resolve competency when bona fide doubt exists)