Jason Wayne Carlile v. The State of Texas

Summary

The Texas Court of Appeals, Second District, Fort Worth, affirmed Jason Wayne Carlile’s convictions for aggravated sexual assault and sexual assault. The court held that Carlile failed to preserve his claims concerning belated discovery disclosures, that the trial court did not abuse its discretion in denying a continuance, and that his attorneys’ intentional nonparticipation in the trial did not warrant relief under ineffective-assistance principles.

Holdings

1. Carlile's claims that the State violated Brady, the Michael Morton Act, due process, and the prosecutor's duty were not preserved because he did not make a timely, specific objection or request identifying those grounds in the trial court.
2. The trial court did not abuse its discretion by denying Carlile's motion for a continuance based on the late-produced FBI and Rose Street records.
3. Carlile was not entitled to relief for ineffective assistance or an unfair trial because he and his attorneys intentionally and knowingly engineered counsel's nonparticipation to create reversible error, and Carlile acquiesced in that strategy. The Cronic presumption of prejudice therefore did not provide relief.

Questions Presented

1. Whether Carlile preserved complaints that the State's belated production of FBI and clinic records violated Brady v. Maryland, the Michael Morton Act, due process, and the prosecutor's statutory duty.
2. Whether the trial court abused its discretion by denying Carlile's motion for a continuance based on recently produced discovery.
3. Whether Carlile was denied effective assistance of counsel and a fair trial when his attorneys intentionally refused to participate in the trial, and whether prejudice should be presumed under United States v. Cronic.

Disposition

affirmed