Reynaldo Antonio Sanchez v. The State of Texas

Summary

The Texas Tenth Court of Appeals affirmed Reynaldo Antonio Sanchez’s conviction for continuous sexual abuse of a young child and forty-year sentence. The court held that Sanchez failed to preserve his constitutional speedy-trial claim and that the trial court properly admitted translated statements from a medical examination under the hearsay and Confrontation Clauses. The court issued the opinion as a memorandum opinion and designated it do not publish.

Holdings

1. A constitutional speedy-trial complaint is subject to Texas error-preservation requirements, and Sanchez failed to preserve his claim because he did not make an unambiguous speedy-trial demand, obtain an adverse ruling, or otherwise alert the trial court that he intended to assert the right.
2. The trial court did not abuse its discretion by admitting the translated statements because the State established the circumstances supporting treatment of the interpreter as a language conduit and each applicable hearsay layer was covered by an exception or was not an additional hearsay layer.
3. Admission of Downing's translated statements did not violate the Sixth Amendment because the statements were non-testimonial and were made primarily to facilitate medical treatment rather than criminal investigation.

Questions Presented

1. Whether Sanchez preserved his constitutional speedy-trial claim for appellate review.
2. Whether the trial court abused its discretion by admitting translated statements in Dr. Battle's testimony and medical report under the hearsay rules.
3. Whether admission of the translated statements violated Sanchez's Sixth Amendment right of confrontation because the interpreter did not testify before the jury.

Disposition

affirmed