Thanh Kim Hoang v. State ( 2015 )

ACCEPTED
01-14-00722-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/25/2015 12:22:22 PM
CHRISTOPHER PRINE
CLERK
01-14-00722-CR
###########
No. 01-14-00772-CR
In the FILED IN
Court of Appeals 1st COURT OF APPEALS
HOUSTON, TEXAS
For the
6/25/2015 12:22:22 PM
First Judicial District of Texas
CHRISTOPHER A. PRINE
At Houston Clerk

No. 1384675
In the 209th District Court of
Harris County, Texas

THANH KIM HOANG
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S APPELLATE BRIEF

DEVON ANDERSON
District Attorney
Harris County, Texas
CARLY DESSAUER
Assistant District Attorney
NATHAN MOSS
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
Tel.: 713/755-5826
Fax No.: 713/755-5809
ORAL ARGUMENT NOT REQUESTED
STATEMENT REGARDING ORAL ARGUMENT
Pursuant to Texas Rule of Appellate Procedure 9.4(g) and Texas Rule of
Appellate Procedure 39.1, the State does not requests oral argument as the issue
involved in this appeal can adequately be determined from the record and established
law but wishes preserve its right to present oral argument if this Court desires to
submit this case through oral argument.
IDENTIFICATION OF THE PARTIES
Pursuant to Texas Rule of Appellate Procedure 38.2(a)(1)(A), a complete list of
the names of all interested parties is provided below.
Counsel for the State:
Devon Anderson  District Attorney of Harris County
Carly Dessauer  Assistant District Attorney on appeal
Nathan L. Moss  Assistant District Attorney at trial
David Bernard  Assistant District Attorney at trial
1201 Franklin Street, Suite 600, Houston, Texas 77002
Appellant or criminal defendant:
Thanh Kim Hoang
Counsel for Appellant:
Charles Hinton  Attorney on appeal
P.O. Box 53719, Houston, Texas 77052
Kurt B. Wentz  Attorney at trial
5629 FM 1960, Suite 115, Houston, Texas 77069
Trial Judge:
Hon. Wayne Mallia
ii
TABLE OF CONTENTS
STATEMENT REGARDING ORAL ARGUMENT .................................................... ii
IDENTIFICATION OF THE PARTIES ......................................................................... ii
TABLE OF AUTHORITIES ............................................................................................. iv
STATEMENT OF THE CASE .......................................................................................... 1
STATEMENT OF FACTS .................................................................................................. 1
SUMMARY OF THE ARGUMENT ................................................................................. 3
REPLY TO APPELLANT’S POINT OF ERROR ......................................................... 3
I. The jury charge did not erroneously instruct the jury on the intent appellant
needed to be a party to capital murder........................................................................... 3
a. The jury charge correctly required that the jury only convict appellant as
a party to capital murder if it found that he had the intent to promote or
assist Bui in killing Tu................................................................................................. 6
b. Assuming for the sake of argument that the jury charge was erroneous,
appellant was not egregiously harmed by the instruction. ................................... 10
CONCLUSION ................................................................................................................... 13
CERTIFICATE OF COMPLIANCE .............................................................................. 14
CERTIFICATE OF SERVICE ......................................................................................... 15
APPENDIX .......................................................................................................................... 16
iii
TABLE OF AUTHORITIES
CASES
Almanza v. State,
686 S.W.2d 157 (Tex. Crim. App. 1984) ................................................................... 4, 10
Holford v. State,
177 S.W.3d 454 (Tex. App.—Houston [1st Dist.] 2005, pet. ref’d) ...................... 9, 10
Nelms v. State,
No. 01-13-00689-CR, 2014 WL 3738065
(Tex. App.—Houston [1st Dist.] July 29, 2014, pet. ref’d)
(mem. op., not designated for publication)................................................................. 7, 8
Ngo v. State,
175 S.W.3d 738 (Tex. Crim. App. 2005) ......................................................................... 4
Vasquez v. State,
389 S.W.3d 361 (Tex. Crim. App. 2012) ...................................................... 4, 5, 7, 8, 12
STATUTES
TEX. CODE CRIM. PROC. ANN. art. 36.14 (West 2007) ...................................................... 5
TEX. PENAL CODE ANN. §7.01(a) (West 2011) .................................................................. 5
TEX. PENAL CODE ANN. §7.02(a)(2) (West 2011) .............................................................. 5
TEX. PENAL CODE ANN. §19.03(a)(2) (West Supp. 2014)................................................. 5
TEX. PENAL CODE ANN. §29.02(a) (West 2011) ................................................................ 5
RULES
TEX. R. APP. P. 9.4(g) ............................................................................................................. ii
TEX. R. APP. P. 9.4(i). ........................................................................................................... 14
TEX. R. APP. P. 38.2(a)(1)(A) ................................................................................................. ii
TEX. R. APP. P. 39.1 ................................................................................................................ ii
iv
TO THE HONORABLE COURT OF APPEALS:
STATEMENT OF THE CASE
Appellant was charged with capital murder (CR at 11). Appellant entered a
plea of not guilty and request a jury trial to determine guilt (CR at 96; 3 RR at 16).
The jury found appellant guilty, and since the State did not seek the death penalty, the
court assessed punishment at confinement for life without parole (CR at 112, 114; 5
RR at 37, 40). The court certified appellant’s right to appeal, and appellant filed a
timely notice of appeal (CR at 117-18).
STATEMENT OF FACTS
Appellant and his co-defendant, Vu Bui, went to Tuan Tu’s game room and
café, Café Chieu Tim (3 RR at 24; 4 RR at 29). The two other patrons present,
brothers Nghiep and Johnny Le, were playing pool when they arrived (3 RR at 123,
125; 4 RR at 13, 14; State’s Ex. 43). Both brothers noticed the men as they were
strangers, and the brothers were used to seeing only regulars at the café (3 RR at 125;
4 RR at 15-16). Indeed, Johnny was uncomfortable with them because, in addition to
not knowing the men, they did not remove their jackets or sunglasses despite being
inside and the weather being hot (3 RR at 126; State’s Ex. 43). Appellant and Bui sat
down at a table and ordered iced coffee (3 RR at 126, 142; 4 RR at 16; State’s Ex. 43).1
After about thirty minutes of sitting, smoking, and occasionally talking with Tu,
1
Appellant’s DNA could not be excluded from DNA found at the scene on a pair of glasses, a glass,
and a cigarette butt (3 RR at 39, 50; 4 RR at 66, 70; State’s 29, 58, 59).
1
appellant and Bui walked up to the three men, and Bui pulled out a gun (3 RR at 127,
148; 4 RR at 17, 18; State’s Ex. 43).
Bui tapped the gun on Johnny’s shoulder as he was facing the pool table and
was unaware of the unfolding robbery (3 RR at 129-30, 143). Appellant was at his
side, ready to assist Bui in controlling the men (3 RR at 131). Bui instructed them to
kneel, and appellant then told Johnny “to lay down” (3 RR at 130, 131, 149; 4 RR at
17, 18). However, Tu, who had a concealed handgun, drew his weapon to defend
himself and his business from appellant and Bui (3 RR at 69, 135). Tu and Bui
exchanged gunfire (3 RR at 135, 136; State’s Ex. 43). Bui shot at Tu until his gun was
empty, hitting Tu twice in the chest and killing him (4 RR at 52; State’s Ex. 43).
Both Bui and appellant fled the scene (3 RR at 138). Appellant was later
apprehended by police, but at the time of trial, Bui had not yet been apprehended (3
RR at 79, 85).
The evidence presented at trial established that Bui, not appellant, had fired the
fatal shots that hit Tu during their robbery, so the trial court instructed the jury that it
could find appellant guilty of capital murder as a principle, party, or co-conspirator to
the offense (CR at 97-103). APPENDIX. The court also instructed the jury on the
lesser included offenses of felony murder and aggravated robbery (CR at 103-106).
Appellant did not object to the charge at trial (4 RR at 101).
2
SUMMARY OF THE ARGUMENT
The trial court did not err when it instructed the jury on appellant’s requisite
mental state to be guilty as a party to capital murder as the charge required the jury to
find that appellant had the intent to promote or assist Bui with the robbery in addition
to the intent to solicit, encourage, direct, aid, or attempt to aid Bui in shooting and
killing Tu. Appellant’s argument focuses on one portion of the jury charge and
ignores that the charge as a whole correctly stated the law regarding party intent.
Analyzed as a whole, the court did not err in its charge, and appellant’s sole point of
error should be overruled.
REPLY TO APPELLANT’S POINT OF ERROR
I. The jury charge did not erroneously instruct the jury on the intent appellant
needed to be a party to capital murder.
In his sole point of error, appellant argues that the trial court erred in charging
the jury on the law of parties when it instructed that before the jury could find
appellant guilty of capital murder as a party, it “must find from the evidence beyond a
reasonable doubt that [appellant] with intent to promote or assist in the commission
of the offense of robbery, if any, solicited, encouraged, directed, aided, or attempted
to aid Vu Bui in shooting Tuan Tu, if he did, with the intention of thereby killing
Tuan Tu” (CR at 101). Appellant alleges that the instruction allowed the jury to find
him guilty as a party if it only found that he had intent to promote or assist the
robbery without also having the intent to promote or assist Tu’s murder. Appellant’s
3
argument focuses on the phrase that instructed the jury that it must find that appellant
had the “intent to promote or assist in the commission of the offense of robbery” to
support his claim (CR at 101). However, as the language of the whole charge shows,
the court did not misinform the jury on appellant’s requisite intent as a party to capital
murder. The instruction, as a whole, correctly required that the jury had to find that
appellant had the intent to assist or promote Bui both in the robbery and in killing Tu.
As such, the court’s instruction was not erroneous.
Standard of Review
A reviewing court’s first duty in analyzing a jury-charge issue is to decide
whether error exists. Ngo v. State, 175 S.W.3d 738, 743 (Tex. Crim. App. 2005). When
examining the charge for possible error, reviewing courts “examine the charge as a
whole instead of a series of isolated and unrelated statements.” Vasquez v. State, 389
S.W.3d 361, 366 (Tex. Crim. App. 2012) (quoting Dinkins v. State, 894 S.W.2d 330, 339
(Tex. Crim. App. 1995)).
Only if the court finds error, it must then conduct a harm analysis depending
on whether the appellant objected to the error. Ngo, 175 S.W.3d at 743. When a
defendant does not object to the court’s charge, the reviewing court can only reverse
if the defendant suffered egregious harm. Almanza v. State, 686 S.W.2d 157, 171 (Tex.
Crim. App. 1984).
4
Applicable Law
A trial court must instruct the jury on the “law applicable to the case” when
charging the jury. TEX. CODE CRIM. PROC. ANN. art. 36.14 (West 2007). “Because
the charge is the instrument by which the jury convicts, [it] must contain an accurate
statement of the law and must set out all the essential elements of the offense.”
Vasquez, 389 S.W.3d at 366 (quoting Dinkins, 894 S.W.2d at 339).
A person commits the offense of capital murder if he intentionally or
knowingly causes the death of an individual in the course of committing or attempting
to commit robbery. TEX. PENAL CODE ANN. §19.03(a)(2) (West Supp. 2014). A
person commits robbery if, in the course of committing theft and with intent to
obtain or maintain control of property, the person intentionally, knowingly, or
recklessly causes or threatens bodily injury to another. TEX. PENAL CODE ANN.
§29.02(a) (West 2011).
“A person is criminally responsible as a party to an offense if the offense is
committed by his own conduct, by the conduct of another for which he is criminally
responsible, or by both.” TEX. PENAL CODE ANN. §7.01(a) (West 2011). To be
criminally responsible for an offense committed by the conduct of another, the
person must act with the intent to promote or assist the commission of the offense by
soliciting, encouraging, directing, aiding, or attempting to aid the other person to
commit the offense. TEX. PENAL CODE ANN. §7.02(a)(2) (West 2011).
5
Analysis
a. The jury charge correctly required that the jury only convict appellant as
a party to capital murder if it found that he had the intent to promote or
assist Bui in killing Tu.
In its instruction, the trial court charged the jury that it could find appellant
guilty as a principle, as a party, and as a co-conspirator to the offense of capital
murder (CR at 97-103). APPENDIX. Regarding the law of parties, the court first
defined criminal responsibility as a party for the jury:
A person is criminally responsible for an offense committed by the
conduct of another if, acting with intent to promote or assist the
commission of the offense, he solicits, encourages, directs, aids, or
attempts to aid the other person to commit the offense (CR at 100-01).
The court then gave the jury an instruction involving the law of parties and appellant’s
charged capital murder:
Before you would be warranted in finding [appellant] guilty of capital
murder, [… ] you must find from the evidence beyond a reasonable
doubt that [appellant], with the intent to promote or assist in the
commission of the offense of robbery, if any, solicited, encouraged,
directed, aided, or attempted to aid Vu Bui in shooting Tuan Tu, if he
did, with the intention of thereby killing Tuan Tu (CR at 101).
Finally, the court gave the jury an application paragraph applying the law of parties to
the facts of appellant’s charged capital murder:
If you find from the evidence beyond a reasonable doubt that on or
about the 8th day of February, 2013, in Harris County, Texas, Vu Bui,
did then and there unlawfully, while in the course of committing or
attempting to commit the robbery of Tuan Tu, intentionally cause the
death of Tuan Tu by shooting Tuan Tu with a deadly weapon, namely a
firearm, and [appellant], with the intent to promote or assist the
6
commission of the offense, if any, solicited, encouraged, directed, aided
or attempted to aid Vu Bui to commit the offense, if he did[…] then you
will find the defendant guilty of capital murder, as charged in the
indictment (CR at 102-03).
As is evident from the charge as a whole, the trial court did not erroneously
instruct the jury on the law of parties in a way that would have allowed the jury to
convict appellant of capital murder if it only found that he had the intent to promote
or assist the commission of the offense of robbery as appellant alleges on appeal. See
Vasquez, 389 S.W.3d at 366 (requiring reviewing courts to review the jury charge as a
whole). As the charge stated in the paragraph appellant claims to be erroneous, the
jury could only find appellant guilty of capital murder if it found that appellant had
both the “intent to promote or assist in the commission of the offense of robbery” and
“solicited, encouraged, directed, aided, or attempted to aid Vu Bui in shooting Tuan
Tu, if he did, with the intention of thereby killing Tuan Tu (CR at 101) (emphasis added).
The charge did not omit the requisite intent to kill as appellant claims.
Indeed, the jury charge in appellant’s case is nearly identical to the charge
recently analyzed by this Court in Nelms v. State. Nelms v. State, No. 01-13-00689-CR,
2014 WL 3738065, at *2 (Tex. App.—Houston [1st Dist.] July 29, 2014, pet. ref’d)
(mem. op., not designated for publication). Nelms, like appellant, was convicted of
capital murder; however, the aggravating element of his offense was the offense of
burglary of a habitation. Nelms, 2014 WL 3738065, at *2. Nelms, like appellant,
complained that the jury charge erroneously allowed the jury to find him guilty as a
7
party to capital murder if it found that he had the intent to be a party to the
aggravating offense when it instructed the jury that “you must find from the evidence
beyond a reasonable doubt that [Nelms], with the intent to promote or assist in the
offense of burglary of habitation.” Nelms, 2014 WL 3738065, at *3 (italics in original).
Nelms, like appellant, argued that the correct instruction should have told the jury that
his intent to promote or assist should have been directed towards the offense of
capital murder instead of his aggravating offense of burglary of a habitation. Nelms,
2014 WL 3738065, at *3. However, appellant, like Nelms, failed to consider the
charge as a whole when making his argument. Nelms, 2014 WL 3738065, at *3 (noting
that jury charge also instructed the jury that it must find that Nelms “solicited,
encouraged, directed, aided, or attempted to aid [Jones] in shooting [Nelson], if he
did, with the intention of thereby killing [Nelson ]”) (italics in original).
For the same reason that this Court rejected Nelms’ argument, this Court
should likewise reject appellant’s identical argument after analyzing the charge as a
whole. See Vasquez, 389 S.W.3d at 366. The court’s entire jury charge involving
appellant’s guilt on theory of the law of parties correctly informed the jury that
appellant needed the intent to promote or assist Bui with the robbery as well as the
intent to promote or assist Bui in killing Tu before it could find appellant guilty of
capital murder as a party (CR at 101, 102-03). See Nelms, 2014 WL 3738065, at *3.
The sentence that appellant focuses on in his argument does mention that appellant
intend to promote or assist the offense of robbery, but the court’s instruction goes on
8
to state that appellant also needed the intent to solicit, encourage, direct, aid, or
attempt to aid Bui in shooting Tu to be criminally responsible as a party to capital
murder (CR at 101). Additionally, the application paragraph set out similar language
as the sentence appellant focuses on in his brief but does not designate the offense of
robbery to be the offense appellant had to intent to commit (CR at 102-03). Instead,
the court instructed the jury that it could find appellant guilty only if it found beyond
a reasonable doubt that appellant intended “to promote or assist the commission of
the offense” (CR at 102-03).
In Holford v. State, this Court upheld the jury charge over Holford’s claim that
the charge allowed the jury to convict him as a party to capital murder if he intended
to aid only in the robbery when the application paragraph “cautioned the jury” that it
must also find intent to kill. Holford v. State, 177 S.W.3d 454, 460, 461 (Tex. App.—
Houston [1st Dist.] 2005, pet. ref’d) (noting that the jury charge read: “Before you
would be warranted in finding the defendant guilty of capital murder, ... you must find
from the evidence beyond a reasonable doubt that the defendant, David Charles
Holford, with the intent to promote or assist in the commission of the offense of robbery, if any,
solicited, encouraged, directed, aided, or attempted to aid Harold Louis Vaughn in cutting or striking
Trevor Cook, if he did, with the intention of thereby killing Trevor Cook”) (italics in original).
In Holford, this Court noted that, when “read logically,” “the clause “solicited,
encouraged, directed, aided or attempted to aid Harold Louis Vaughn to commit the
offense” refers to the complainant’s murder. Holford, 177 S.W.3d at 461. The same
9
logical reading applies to the party instruction in appellant’s charge in which the clause
“solicited, encouraged, directed, aided, or attempted to aid Vu Bui in shooting Tuan
Tu” refers to Tu’s murder (CR at 101).
Because the charge as a whole directed the jury that it needed to find that
appellant had the intent to kill Tu before it could find him guilty as a party to capital
murder, the court’s charge is not erroneous. Therefore, this Court should overrule
appellant’s argument.
b. Assuming for the sake of argument that the jury charge was erroneous,
appellant was not egregiously harmed by the instruction.
Assuming for the sake of argument that the trial court’s charge erroneously
instructed the jury regarding the required intent appellant needed to be guilty of
capital murder as a party, appellant’s conviction does not require reversal. Almanza,
686 S.W.2d at 171 (requiring that the defendant who does not object to the court’s
charge at trial to suffer egregious harm to obtain a reversal). Had the trial court’s
charge on party intent been erroneous, appellant, who did not object to the court’s
charge at trial, was not egregiously harmed by the jury instruction (4 RR at 101).
Standard of Review
To determine whether a defendant has sustained egregious harm from a jury
instruction, the reviewing court considers (1) the entire charge; (2) the state of the
evidence, including contested issues; (3) arguments of counsel; and (4) any other
relevant information. Holford, 177 S.W.3d at 461.
10
Analysis
The jury charge did not egregiously harm appellant because, not only did the
charge correctly instruct the jury correctly on the law of parties, the court also
instructed the jury that appellant could be guilt as the primary actor or as a
conspirator to the offense. While the evidence would not have supported appellant’s
conviction as a primary, the evidence proved beyond a reasonable doubt that
appellant was guilty as a party as well as a co-conspirator, and the jury could have
found him guilty under either theory.
Eyewitness testimony, surveillance video, and DNA evidence put appellant at
the scene of the offense (3 RR at 39, 50, 125-26; 4 RR at 13, 66, 70; State’s 29, 40; 43,
58, 59). The evidence showed that appellant and Bui entered the café together and
that they did not need to tell each other what they were doing when they initiated the
robbery, inferring prior planning (3 RR at 123, 125, 127, 147-48; 4 RR at 18). The
evidence established that appellant acted in concert with Bui by following him, ready
to provide assistance when Bui threated Tu and the Le brothers with his loaded gun,
and appellant instructed the robbery victims to comply with their demands (3 RR at
129-31). Indeed, Johnny testified that when Bui placed his gun on his shoulder,
appellant instructed him to lay down on the ground (3 RR at 149). Further, both Le
Brothers testified that appellant was not surprised or afraid when Bui pulled out his
gun (3 RR at 147, 149; 4 RR at 19, 20).
11
The arguments of counsel also establish that appellant was not egregiously
harmed by the trial court’s instruction as both the State and appellant’s statements to
the jury agreed that the evidence only supported appellant’s guilt as a party or co-
conspirator and both discussed the requisite intent appellant needed to be a party to
capital murder (5 RR at 5, 8, 9, 14, 25). See Vasquez, 389 S.W.3d at 371-72 (discussing
how both the prosecutor and Vasquez discussed party liability in their closing
arguments when holding the jury charge error harmless). Appellant’s argument
pointed the jury to the lesser included offenses of felony murder and aggravated
robbery because appellant claimed that the evidence did not support his intent to kill
Tu (5 RR at 8, 9-10). Because the arguments of counsel reiterated to the jury that
appellant needed to intend to kill Tu to be guilty as a party to capital murder, he was
not egregiously harmed by the error, if any, in the jury charge.
Indeed, the record, through the entire jury charge, the state of the evidence,
and the arguments of counsel, supports that even if the trial court erred in its jury
instruction on the intent needed for the jury to find appellant guilty as a party to
capital murder, appellant was not egregiously harmed by the error. However, this
Court does not need to depend upon an analysis of harm to uphold appellant’s
conviction as the trial court did not err in its charge. Therefore, this Court should
overrule appellant’s sole point of error.
12
CONCLUSION
Based on the arguments stated above, the State of Texas respectfully urges the
Court to overrule appellant’s point of error and affirm his conviction.
DEVON ANDERSON
District Attorney
Harris County, Texas
/s/ Carly Dessauer
____________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
curry_alan@dao.hctx.net
13
CERTIFICATE OF COMPLIANCE
The undersigned attorney certifies that this computer-generated document has
a word count of 3,238 words, based upon the representation provided by the word
processing program that was used to create the document. TEX. R. APP. P. 9.4(i).
/s/ Carly Dessauer
____________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
14
CERTIFICATE OF SERVICE
The State will serve a copy of the foregoing instrument to appellant’s attorney
though TexFile:
Charles Hinton
Attorney at Law
P.O. Box 53719
Houston, Texas 77052-3719
chashinton@sbcglobal.net
/s/ Carly Dessauer
____________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
Date: June 25, 2015
15
APPENDIX
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I, Chris Daniel, District Clerk of Harris
County, Texas certify that this is a true and
correct copy of the original record filed and or
recorded in my office, electronically or hard
copy, as it appears on this date.
Witness my official hand and seal of office
this June 19, 2015
Certified Document Number: 62067440 Total Pages: 17
Chris Daniel, DISTRICT CLERK
HARRIS COUNTY, TEXAS
In accordance with Texas Government Code 406.013 electronically transmitted authenticated
documents are valid. If there is a question regarding the validity of this document and or seal
please e-mail support@hcdistrictclerk.com