Ruben Andres Baldez v. State, 13-14-00257-CR

Ruben Andres Baldez was tried for misdemeanor driving while intoxicated (DWI) after a September 2013 vehicle collision; officers and the complaining driver testified to signs of intoxication (odor of alcohol, glassy eyes, staggered gait, slurred speech) and a beer can was found near Baldez’s vehicle.
Baldez testified in his own defense, claiming he was not intoxicated, disputing the other driver’s account, and offering injury as an alternative explanation for his gait and conduct.
On cross-examination the State asked Baldez whether he was a convicted felon; after a bench conference the trial court allowed the State to impeach Baldez with a prior felony conviction (possession of methadone, 2008). Baldez objected as unfairly prejudicial.
The trial court permitted only the fact of the prior conviction (no documentary proof) and did not announce detailed findings of fact or conclusions on the Rule 609 balancing; Baldez did not request such findings or a limiting instruction.
The jury found Baldez guilty of DWI. The State argues on appeal the trial court did not abuse discretion admitting the prior conviction under Tex. R. Evid. 609; alternately, any error was harmless given the strength of the State’s evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Baldez)	Held (trial court / State position on appeal)
Admissibility of prior felony to impeach (Rule 609)	Prior methadone conviction was recent, low risk of inflammatory prejudice, and Baldez’s credibility (as sole defense witness for key facts) made impeachment probative	Prior conviction is unfairly prejudicial and unrelated to DWI; should be excluded	Trial court allowed impeachment; State contends appellate court should affirm because Theus factors favor admission
Requirement to announce findings/conclusions when admitting 609 evidence	Not required; trial court is encouraged but its balancing may be presumed from the record and bench hearing	Trial court erred by not announcing findings on the record	State: no duty to announce; no objection at trial waived any claim; presumption court performed balancing
Scope of cross-examination about prior conviction	Eliciting the fact of conviction was a proper, limited impeachment method	Such inquiry unfairly prejudiced the jury and could influence verdict	Trial court limited scope; State argued limited inquiry minimized prejudice
Harmless-error analysis if admission was erroneous	Any error harmless because State’s evidence of intoxication was strong and prior drug felony was unlikely to inflame jury	Admission of felony conviction substantially affected Baldez’s substantial rights	State: error (if any) was non-constitutional and harmless under Tex. R. App. P. 44.2(b) given record strength

Theus v. State, 845 S.W.2d 874 (Tex. Crim. App. 1992) (articulates five-factor Rule 609 balancing test and standard of review for prior-conviction impeachment)
Bagheri v. State, 119 S.W.3d 755 (Tex. Crim. App. 2003) (harmless-error standards for non-constitutional evidentiary errors)
Motilla v. State, 78 S.W.3d 352 (Tex. Crim. App. 2002) (appellate review considers entire record in harm analysis)
King v. State, 953 S.W.2d 266 (Tex. Crim. App. 1997) (substantial-rights test for non-constitutional error)
Poiter v. State, 68 S.W.3d 657 (Tex. Crim. App. 2002) (classification of non-constitutional evidentiary errors)
Herring v. State, 147 S.W.3d 390 (Tex. Crim. App. 2004) (propensity concerns when prior offenses similar to charged offense)
Mireles v. State, 413 S.W.3d 98 (Tex. App.—San Antonio 2013) (discusses importance of defendant testimony and sufficiency of Theus-factor mix to uphold admission)
Yanez v. State, 199 S.W.3d 293 (Tex. App.—Corpus Christi 2006) (strength of other evidence reduces likelihood improperly admitted prior-conviction evidence affected verdict)