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Cedric Middleton v. State
Citation: Not availableDocket: 03-03-00268-CR
Court: Court of Appeals of Texas; April 22, 2004; Texas; State Appellate Court
Original Court Document: View Document
Cedric Middleton was convicted by a jury for possessing over four grams of cocaine, leading to a 26-year prison sentence due to enhancements from two prior felony convictions. Middleton raised two points of error: ineffective assistance of counsel and denial of a hearing on his motion for a new trial. The court overruled these claims and affirmed the conviction. Middleton contended that the trial court abused its discretion by denying a hearing on his motion for new trial without addressing its merits. The State argued that the motion was untimely, but evidence indicated it was filed on April 30, 2003, within the deadline following the sentencing on April 1, 2003. The court confirmed the timeliness of the motion. In his motion for new trial, Middleton claimed his attorney failed to file a motion to suppress evidence of the cocaine, which he argued was seized unlawfully during his arrest. He asserted that the arresting officers did not inform him of the reasons for his arrest, violating Texas Code of Criminal Procedure article 15.26, which mandates that an officer must inform the accused of the authority and grounds for arrest. The district court noted that there were no grounds for a hearing or for a new trial under Texas or constitutional law. Middleton maintained he deserved a hearing to present evidence on the officers' compliance with the statute and his attorney's failure to address this issue, asserting that a violation of article 15.26 warranted suppression of the evidence obtained during the arrest. In *Jones v. State*, the court determined that noncompliance with article 15.26 does not invalidate an arrest or necessitate the suppression of evidence obtained from it. Although the appellant accepts this ruling, he contends that it is no longer valid following *Chavez v. State*, where the court addressed a defendant's attempt to suppress evidence based on an alleged violation of a task-force agreement. The *Chavez* decision clarified that only parties to the agreement have standing to raise such violations and did not involve article 15.26. The court found no reason to question the continued validity of *Jones* based on *Chavez*. Consequently, even if a hearing had addressed a violation of article 15.26, the appellant's counsel could not be deemed ineffective for failing to raise a baseless objection. The district court did not err in concluding that the appellant's motion for a new trial did not present a valid claim for relief and refused to hold a hearing. The first point of error was overruled, and the second point, reiterating the ineffectiveness claim regarding the lack of an article 15.26 objection, was also overruled. The conviction was affirmed.