Manuel Mata v. the State of Texas

Summary

The Seventh Court of Appeals of Texas affirmed Manuel Mata’s conviction for interference with public duties, a Class B misdemeanor. The court held that Mata’s as-applied constitutional challenge was not preserved, that the evidence was legally sufficient to show criminally negligent interference with a peace officer’s investigation, and that any error from including the term “belligerent” in the jury charge was harmless.

Holdings

1. Mata failed to preserve his as-applied constitutional challenge because he sought suppression of evidence rather than dismissal of the charging instrument and did not present the as-applied challenge to the trial court.
2. The evidence was legally sufficient for a rational jury to find beyond a reasonable doubt that Mata, with criminal negligence, interfered with a peace officer performing lawful duties.
3. The inclusion of "belligerent" did not require reversal. The term described one alternative manner and means of committing the offense, and any error was harmless because the evidence supported the other three charged manners and means.

Questions Presented

1. Whether Mata preserved an as-applied constitutional challenge to Texas Penal Code section 38.15 by filing and renewing a motion to suppress rather than moving to dismiss the charging instrument.
2. Whether legally sufficient evidence supported Mata's conviction for criminally negligent interference with a peace officer.
3. Whether the trial court reversibly erred by including the term "belligerent" in the jury charge.

Disposition

affirmed