Randy Antonio Estrada v. the State of Texas
02-20-00156-CR
| Tex. App. | May 5, 2022Background
- Tarrant County lodged an IADA detainer against Estrada while he was incarcerated in Ohio; the State received his final-disposition request on Jan. 23, 2020, starting a 180-day IADA clock (originally expiring July 21, 2020).
- COVID-19 caused cancellation of jury trials; Estrada consented to a continuance in June and the trial court granted a July 13 continuance for good cause under IADA, which the court later treated as tolling the IADA period.
- The trial court initially dismissed the indictment on Sept. 11 but reinstated it after reconsideration, finding tolling and good cause extended the IADA period through Oct. 25, 2020.
- The local jury-trial plan was approved Oct. 23; the court announced trial would begin Oct. 26, and Estrada expressly said on Oct. 15 he had no objections to proceeding under the plan and filed no objection by the court’s Oct. 19 deadline.
- On Oct. 26 (first day of trial) Estrada moved to dismiss under the IADA, arguing the 180-day deadline expired on Sunday Oct. 25; the trial court denied the motion, convicted Estrada of indecency-with-a-child counts, and he appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Waiver of IADA objection by failing to object to trial date | Estrada contends deadline expired and trial after Oct. 25 violated IADA | State: Estrada consented at Oct. 15 hearing and filed no timely objection by Oct. 19 | Court: Waived — Estrada’s affirmative consent and failure to timely object bars the claim |
| Whether IADA deadline ending Oct. 25 was expired despite falling on Sunday | Estrada: 180-day period ended Oct. 25, so trial Oct. 26 violated IADA | State: Deadlines falling on weekend extend to next business day; Oct. 25 extended to Oct. 26 | Court: Deadline automatically extended to Monday Oct. 26 |
| Whether trial court could effectively extend/start trial on Oct. 26 without a party’s continuance motion | Estrada: Good cause must be shown by a party in open court; court cannot sua sponte extend IADA deadline to Oct. 26 | State: Court may sua sponte grant necessary/reasonable continuance when prisoner and counsel are present; Oct. 23 plan approval and pandemic presented good cause | Court: Trial court could sua sponte permit trial on Oct. 26 for good cause and did not abuse discretion |
Key Cases Cited
- State v. Votta, 299 S.W.3d 130 (Tex. Crim. App. 2009) (explaining IADA’s purpose and procedures)
- Celestine v. State, 356 S.W.3d 502 (Tex. App.—Houston [14th Dist.] 2009) (IADA construction and purpose)
- Carchman v. Nash, 473 U.S. 716 (1985) (IADA is a congressionally sanctioned compact subject to federal construction)
- New York v. Hill, 528 U.S. 110 (2000) (defendant’s consent to continuance can constitute waiver of speedy-trial objections)
- Birdwell v. Skeen, 983 F.2d 1332 (5th Cir. 1993) (recognizing trial court may sua sponte grant reasonable continuance under IADA when prisoner and counsel are present)
- Barbee v. State, 432 S.W.2d 78 (Tex. Crim. App. 1968) (application of rule extending statutory deadlines that fall on weekend)
- Lasker v. State, 577 S.W.3d 583 (Tex. App.—Houston [1st Dist.]) (standard of review for IADA dismissal denials)