William Thomas Leonard v. State
376 S.W.3d 886
| Tex. App. | 2012Background
- Leonard’s bond was set by the Court of Criminal Appeals pending discretionary review.
- The trial court added conditions to Leonard’s bond after the CCA set the amount.
- Leonard pleaded guilty to injury to a child, received deferred adjudication, five-year term, and a $750 fine.
- Conditions included sex offender evaluation/counseling and polygraph requirements; State sought adjudication of guilt due to alleged violations.
- Eastland Court of Appeals reversed the trial court’s revocation based on polygraph evidence; CCA granted discretionary review and bail pending appeal at $20,000.
- Leonard challenged the trial court’s authority to impose bond conditions; the court upheld the conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court could set bond conditions under 44.04(c) | Leonard: trial court lacked authority to impose conditions on bond set by CCA. | Leonard: doesn’t address authority; State: trial court can impose reasonable bail conditions. | Trial court may impose reasonable bond conditions |
| Law of the case doctrine applicability to bail conditions | Leonard: law of the case prevents imposing conditions since CCA did not impose them. | Leonard: no resolution on conditions; law of the case applies. | Law of the case does not apply |
Key Cases Cited
- Ex parte Anderer, 61 S.W.3d 398 (Tex. Crim. App. 2001) (explains bail categories and trial court’s authority to impose conditions)
- Abbott v. State, 245 S.W.3d 23 (Tex. App.—Waco, 2007) (applies 44.04(h) to bail decisions on reversed matters)
- Mahaffey v. State, 364 S.W.3d 908 (Tex. Crim. App. 2012) (statutory interpretation of 44.04 with extratextual factors)
- Yates v. State, 679 S.W.2d 538 (Tex. App.—Tyler 1984) (discusses evidence, hearings, and conditions of bail pending appeal)
- Hirsch v. State, 282 S.W.3d 196 (Tex. App.—Fort Worth 2009) (statutory construction standard in this jurisdiction)