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Jeffrey Steven Marx v. State

Citation: Not availableDocket: 01-14-00109-CV

Court: Court of Appeals of Texas; December 21, 2015; Texas; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves an inmate, convicted of aggravated sexual assault of a child, who was ordered by the trial court to have funds withdrawn from his inmate account to satisfy fines and court costs. This order was governed by Texas Government Code Section 501.014(e) as a civil proceeding distinct from the original criminal case. The Court of Appeals for the First District of Texas addressed the issue of whether such an order constitutes a final, appealable order. Citing precedent, the court concluded that the withdrawal order acts as a notification to prison officials, thus lacking the finality required for appeal. Furthermore, the court emphasized that appeals are permissible only for final orders denying motions to modify or rescind such withdrawals, none of which were present in the current case. Acknowledging the jurisdictional limitations, the inmate filed a motion to dismiss his appeal, which the court granted, resulting in the dismissal of the appeal and all pending motions as moot. The decision was rendered per curiam by Justices Higley, Huddle, and Lloyd.

Legal Issues Addressed

Appellate Jurisdiction for Inmate Fund Withdrawals

Application: An inmate may appeal only a final order denying a motion to modify or rescind a withdrawal, which was absent in this case.

Reasoning: While an inmate can appeal a final order denying a motion to modify or rescind a withdrawal, no such order was present in Marx's record.

Finality of Orders for Withdrawal of Inmate Funds

Application: An order to withdraw funds is considered a notification to prison officials and not a final, appealable order.

Reasoning: The Court of Appeals for the First District of Texas determined that the order to withdraw funds is not a final, appealable order, referencing prior case law indicating it functions merely as a notification to prison officials.

Withdrawal of Inmate Funds under Texas Government Code Section 501.014(e)

Application: The court ruled that the withdrawal of funds from an inmate account to cover fines and court costs is a civil proceeding separate from the original criminal case.

Reasoning: The Texas Government Code Section 501.014(e) governs such withdrawals, stating they are civil proceedings separate from the original criminal case.