Leetta Wiley Smith v. State

Citation: Not availableDocket: 02-06-00340-CR

Court: Court of Appeals of Texas; March 5, 2008; Texas; State Appellate Court

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Leetta Wiley Smith was convicted of murder by a jury, receiving a sentence of twenty years' confinement and a $5,000 fine. The incident occurred on July 27, 2002, when Smith stabbed Victor Greer in an apartment in Wichita Falls, Texas. Greer later died from stab wounds, with the fatal wound penetrating his chest and perforating his aorta. After the stabbing, Smith initially left the scene but returned and identified herself to the police. During police interviews, she recounted the events leading up to the stabbing, claiming self-defense amid an argument over a prior incident.

Smith contended that the trial court erred in admitting her confession, arguing it was not made voluntarily due to emotional distress. Although she acknowledged that no coercive tactics were used during the confession, she asserted her will was overborne. Smith filed a motion to suppress the confession, claiming it did not comply with Miranda rights and Texas law. However, the trial court found her statement to be voluntary, noting that she initiated contact with police, was not under arrest during the interview, received appropriate warnings, and that the confession was given voluntarily. The court denied Smith's motion to suppress, leading to her appeal.

Smith's counsel objected to the admission of a video interview at trial, but no further arguments were made, leading the court to allow the evidence. The appellate review of a trial court's ruling on evidence suppression follows a bifurcated standard: deference is given to the trial court's factual determinations, particularly those involving credibility, while "mixed questions of law and fact" are reviewed de novo. If the trial court provides explicit fact findings, they are evaluated in the light most favorable to the court's ruling.

Statements made by an accused are admissible if they are freely and voluntarily given, without coercion, as per Texas law. The voluntariness of a confession is determined by examining the totality of the circumstances surrounding its acquisition. A confession is deemed involuntary if there is evidence of coercive conduct that would negate free choice. Emotional states, confusion, and debilitation can impact voluntariness but do not automatically invalidate a confession.

In Smith's case, the transcript reveals significant emotional distress after learning of Greer’s death, with Smith expressing confusion about her rights during the interview. Officer Haldane attempted to clarify Smith’s understanding and offered her breaks to calm down. The interaction indicated no coercive behavior from the officer; instead, accommodations were made to ensure Smith's comfort, and she was repeatedly informed that she was not obligated to speak. Overall, the evidence did not support claims of coercion, affirming the trial court's ruling on the admissibility of Smith's statement.

Smith's emotional state is a factor in evaluating the voluntariness of her statement to police, but it does not alone render the statement involuntary, as established in Ballestro. The trial court's decision to deny Smith's motion to suppress and admit her video statement into evidence is upheld. Regarding the second issue, Smith contends that the trial court made an error by allowing her husband, Dewan Smith, to testify about an extraneous offense from 2001, where Smith threatened him with a knife. Smith argues that the probative value of this evidence was outweighed by unfair prejudice, referencing Texas Rule of Evidence 403, which allows for exclusion of relevant evidence if it poses significant risks of unfair prejudice or confusion. The court reviews such decisions for abuse of discretion and will affirm if reasonable. The balancing test includes weighing the evidence's probative force against its potential to distract or mislead the jury. Given Smith's self-defense claim, the State introduced Dewan's testimony to counter her defense, showing that Smith had previously displayed violent behavior. Dewan recounted an incident where Smith nicked him with a knife during an argument, indicating this was relevant to the State's rebuttal of her self-defense argument.

Dewan testified that he did not believe Smith intentionally tried to hurt him, nor did he view the incident as an accident. Smith contends that the accidental nature of the Dewan incident and the murder charge against Greer indicate no pattern of criminal behavior, arguing the extraneous offense lacks probative value. However, the testimony is relevant as it suggests Smith's past aggressor behavior in similar contexts, supporting the assertion that she was the initial aggressor in the Greer incident. The State's need for this evidence is heightened due to Smith’s claims of abuse by Greer, which were extensively presented by her witnesses. 

The assessment of unfair prejudice indicates that while evidence may be prejudicial, it is only considered unfair if it adversely affects the defendant beyond proving the relevant fact. Dewan's testimony, while mentioning a scar from the incident, was not deemed overly shocking and did not distract from the trial's main issues. The trial court limited the focus on this testimony, and the jury was instructed to consider it solely for rebutting Smith’s defensive claims. Although Smith raised concerns that the accidental nature of the first incident could mislead the jury into perceiving a criminal pattern, the court found that the factors supporting admission outweighed this potential concern. Consequently, the court affirmed the trial’s judgment, overruling Smith's issues.