Quentin Washington v. The State of Texas

Summary

This document is Quentin Washington’s petition for discretionary review to the Texas Court of Criminal Appeals challenging the affirmance of his convictions for five counts of aggravated sexual assault. It contests the admission of cell-phone extraction reports and chlamydia urinalysis results, arguing that the State failed to establish evidentiary reliability, proper chain of custody, and sufficient authentication. The document also includes the Second Court of Appeals memorandum opinion affirming the trial court’s judgment.

Holdings

1. The trial court did not abuse its discretion by admitting the cell-phone extraction reports because the officers' testimony, together with the mother's and Rita's testimony, empirically showed that the extractions accurately copied and displayed text-message exchanges from their phones.
2. The trial court did not abuse its discretion by admitting the chlamydia-test results because the evidence established the beginning and end of the urine sample's chain of custody and contained no affirmative evidence of tampering or alteration.

Questions Presented

1. Whether the trial court abused its discretion by admitting printouts from UFED Cellebrite extractions of cell phones without additional proof concerning the device's scientific reliability, maintenance, operation, or the operators' qualifications.
2. Whether the trial court abused its discretion by admitting chlamydia-test results when the State did not establish every intermediate link in the urine sample's chain of custody.

Disposition

affirmed