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Erik James Mendoza v. State
Citation: Not availableDocket: 03-02-00079-CR
Court: Court of Appeals of Texas; February 26, 2003; Texas; State Appellate Court
Original Court Document: View Document
Erik James Mendoza was convicted of evading arrest by a jury in the County Court at Law of Comal County, receiving a sentence of 220 days of incarceration and an $800 fine, which was suspended in favor of community supervision. Mendoza appealed, arguing that the trial court erred in admitting a statement he made in custody, which he claimed was the result of custodial interrogation without being advised of his rights. During the trial, Officer John Sullivan testified that he overheard Mendoza claim to be traveling at 160 miles per hour while in the jail's booking area. Mendoza objected to this testimony on hearsay and custodial interrogation grounds, but the objection was overruled. A pretrial hearing had previously suppressed statements made to the arresting officer immediately after the stop, but the admissibility of the later statements was left unresolved until trial. Mendoza sought a new trial, contending that the admission of the overheard statement was improper due to the lack of rights advisement and that he had not intended to affirm his earlier statements to the arresting officer. However, the trial court ruled that his objections were not timely raised, and the motion for a new trial was denied without a hearing. Mendoza's attempt to present evidence about his questioning at the jail was deemed too late, and he did not adequately support his claim under the established precedent. The appellate court found that Mendoza's arguments were not preserved properly and ultimately affirmed the conviction. The ruling emphasized that objections to evidence must be timely and that Mendoza's own testimony did not substantiate his claims regarding the overheard statement.