Cadwallader Coles v. the State of Texas

Summary

The Texas Court of Appeals for the First District affirmed Cadwallader Coles’s conviction for sexual assault and six-year prison sentence. The court held that the complainant’s prompt report and testimony, corroborated by DNA evidence, were legally sufficient to establish sexual contact. The opinion also addresses the admissibility of evidence concerning drugs, drug paraphernalia, and a crack pipe discovered during a jail search.

Holdings

1. The evidence was legally sufficient for a rational jury to find beyond a reasonable doubt that Coles caused his sexual organ to contact Jeff's mouth without Jeff's consent.
2. The trial court did not abuse its discretion by admitting evidence that Coles displayed a white rock, burned glass object, and lighter immediately after the alleged assault.
3. The trial court did not abuse its discretion by admitting evidence of drugs and drug paraphernalia found in the CT scan-room control area.
4. The trial court did not abuse its discretion by admitting evidence that a crack pipe was found during Coles's strip search at the Harris County jail.

Questions Presented

1. Whether legally sufficient evidence supported Coles's sexual-assault conviction.
2. Whether the trial court abused its discretion by admitting evidence of drugs and drug paraphernalia displayed after the assault and found in the CT scan-room control area under Texas Rules of Evidence 404(b) and 403.
3. Whether the trial court abused its discretion by allowing the State to reopen its case and introduce evidence of a crack pipe found during Coles's strip search at the Harris County jail under Rule 404(b).

Disposition

affirmed