JoDaniel Reyna v. the State of Texas

Summary

The Thirteenth Court of Appeals of Texas affirmed JoDaniel Reyna’s conviction for aggravated assault of a public servant and his twenty-eight-year prison sentence. The court held that Reyna failed to preserve several arguments concerning excluded evidence and that the trial court did not abuse its discretion in denying his motion for new trial.

Holdings

1. Reyna waived his appellate complaints based on the Confrontation Clause and Texas Rules of Evidence 412 and 613(b) because he did not present those grounds to the trial court with sufficient specificity.
2. The officer's character was not an essential element of Reyna's claim of self-defense or defense of another, so Rule 405(b) did not authorize admission of the specific prior acts.
3. Reyna waived his motion-for-new-trial complaints by failing to provide a reporter's record of the hearing, because the omitted record was necessary to determine whether the affidavit and other evidence were presented and admitted.
4. The prosecutor's single border-related comment did not warrant reversal because the trial court sustained the objection and instructed the jury to disregard it, and the comment was not so extreme or inflammatory that the instruction was ineffective.

Questions Presented

1. Whether the trial court abused its discretion by excluding disciplinary records concerning the arresting officer's prior misconduct.
2. Whether the trial court abused its discretion by denying Reyna's motion for new trial based on alleged jury manipulation or receipt of unrequested evidence and an allegedly inflammatory, race-based closing argument.

Disposition

affirmed