Background
Jacori Devon Chandler was convicted of evading arrest or detention with a motor vehicle and sentenced to seven years in prison. The trial court suspended the sentence and placed him on community supervision for seven years.
On appeal, Chandler argued that the trial court should have required the State to run criminal-history checks on all prosecution witnesses and disclose the results. He also challenged the denial of his motion for new trial based on an apparent disciplinary action involving a prosecutor in another case and argued that he should have been permitted to question prospective jurors about the legal distinction between hemp and marijuana.
The Court’s Holding
The Tenth Court of Appeals affirmed. It held that neither Brady v. Maryland nor article 39.14 of the Texas Code of Criminal Procedure required the State to search for potentially exculpatory information or create a document by conducting criminal-history checks for the defense.
The court concluded that Chandler’s new-trial claim presented nothing for review because it lacked supporting legal authority and record citations. It also held that the trial court acted within its discretion by barring voir dire about hemp and marijuana because Chandler was charged with evading arrest or detention, motive was not an element of that offense, and the proposed questioning was therefore not a proper area of inquiry.
Key Takeaways
- Brady and article 39.14 do not independently require prosecutors to search for exculpatory material or generate criminal-history reports for the defense.
- An appellate issue unsupported by legal authority and record citations may be rejected as inadequately briefed.
- A trial court may prohibit voir dire on the hemp-marijuana distinction when that subject is irrelevant to the charged offense and concerns motive rather than an offense element.
Why It Matters
The decision reinforces limits on the prosecution’s discovery obligations in Texas criminal cases: the State must disclose qualifying material in its possession, but it need not conduct defense-requested investigations or create new records.
It also underscores that voir dire must address a proper area of inquiry tied to issues the jury must decide, and that appellate arguments must be supported with both authority and citations to the record.