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Jacori Devon Chandler v. the State of Texas

2026-08-20

Summary

Holding. The trial court's judgment convicting Chandler of evading arrest or detention with a motor vehicle was affirmed.

Chandler was convicted of evading arrest or detention with a motor vehicle and received a seven-year suspended sentence with community supervision. On appeal, he raised three challenges to the trial court's decisions. First, he argued the trial court should have ordered the State to conduct criminal background checks on its witnesses as part of Brady discovery obligations. The court rejected this claim, finding that neither Brady nor Texas law requires prosecutors to independently search for or create exculpatory materials that a defendant requests. Second, Chandler claimed the trial court erred in denying his motion for new trial based on a prosecutor's disciplinary action in an unrelated case, but this issue was rejected because Chandler failed to provide proper legal citations and record references. Third, Chandler sought to question jurors during voir dire about the legal distinction between hemp and marijuana, apparently to suggest any marijuana smell might have been legal hemp rather than a motive to flee. The court found this line of questioning improper because motive is not an element of the evading arrest charge, making such questioning outside the proper scope of voir dire.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether prosecutors must independently conduct criminal background checks on witnesses in response to Brady discovery demands
  • Sufficiency of briefing on appeal regarding a prosecutor's disciplinary action
  • Whether the trial court abused its discretion by limiting voir dire questioning about hemp versus marijuana when motive is not an element of evading arrest

Procedural posture

Appeal from a conviction in Navarro County Court at Law to the Tenth Appellate District of Texas.

Authorities cited

Opinion

majority opinion

Court of Appeals

Tenth Appellate District of Texas

10-25-00022-CR

Jacori Devon Chandler,

Appellant

v.

The State of Texas,

Appellee

On appeal from the

County Court at Law of Navarro County, Texas

Judge Amanda Doan Putman, presiding

Trial Court Cause No. C41376-CR

JUSTICE HARRIS delivered the opinion of the Court.

MEMORANDUM OPINION

Jacori Devon Chandler was convicted of evading arrest or detention with

a motor vehicle and sentenced to seven years in prison. His sentence was

suspended, and he was placed on community supervision for seven years. We

affirm the trial court’s judgment.

BRADY EVIDENCE

In this first issue, Chandler complains that the trial court erred in failing to order the State to comply with Chandler’s Brady request. See Brady v.

Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963). Specifically,

Chandler wanted the trial court to require the State to run criminal history

checks on all of its witnesses and to provide Chandler those results.

Neither Brady nor article 39.14 of the Texas Code of Criminal Procedure

(which Chandler includes in his argument on this issue) requires the State to

search for exculpatory material or create any document for the defendant. See

Diez v. State, 693 S.W.3d 899, 922 (Tex. App.—Austin 2024, no pet.) (State not

required to perform the type of forensic analysis on cell phone that defendant

wanted); In re State ex rel. Munk, 448 S.W.3d 687, 692-93 (Tex. App.—Eastland

2014, orig. proceeding) (prosecution need not have performed search on

database of criminal histories); In re Watkins, 369 S.W.3d 702, 706-07 (Tex.

App.—Dallas 2012, orig. proceeding) (same); see also Mitchell v. State, No. 01-23-00251-CR, 2024 Tex. App. LEXIS 312, at *15-17 (Tex. App.—Houston [1st

Dist.] Jan. 18, 2024, no pet.) (not designated for publication) (State has no

independent duty per Brady or article 39.14 to seek out information for the

defendant); Coleman v. State, 577 S.W.3d 623, 634-35 (Tex. App.—Fort Worth

2019, no pet.) (similar conclusion under article 39.14); cf. Harm v. State, 183

S.W.3d 403, 407 (Tex. Crim. App. 2006) (under Brady, “the [S]tate is not

required to seek out exculpatory evidence independently on appellant's

Chandler v. State Page 2 behalf”). Chandler’s first issue is overruled.

MOTION FOR NEW TRIAL

Chandler next complains that the trial court erred in denying his motion

for new trial based on an apparent disciplinary action regarding one prosecutor

for the State which occurred in a different case after Chandler’s conviction.

Chandler provides no case authority or record citations to support his

complaint. See TEX. R. APP. P. 38.1(i); Neville v. State, 622 S.W.3d 99, 104 (Tex.

App.—Waco 2020, no pet.). Thus, this issue is improperly briefed and presents

nothing for review. See id.; Solis v. State, 726 S.W.3d 394, 412 (Tex. Crim.

App. 2025); Lucio v. State, 351 S.W.3d 878, 896 (Tex. Crim. App. 2011); Busby

v. State, 253 S.W.3d 661, 673 (Tex. Crim. App. 2008) (affirming that this Court

has no obligation “to construct and compose” a party's “issues, facts, and

arguments with appropriate citations to authorities and to the record”

(internal quotes omitted)).

VOIR DIRE

In his last issue, Chander asserts the trial court erred in denying him

the opportunity to conduct voir dire on a subject directly relevant to the State’s

theory of the case: that Chandler ran because he was in possession of

marijuana. Chandler wanted to question the jury about the legal difference

between hemp and marijuana.

Chandler v. State Page 3

A trial court has broad discretion over the voir dire process. Samaripas

v. State, 454 S.W.3d 1, 5 (Tex. Crim. App. 2014); Barajas v. State, 93 S.W.3d

36, 38 (Tex. Crim. App. 2002). Its discretion is abused only when a proper

question about a proper area of inquiry is prohibited. Id.

Here, before the start of voir dire, the State objected to Chandler’s

potential use of a slide in his voir dire presentation about the “Farm Bill of

2018” regarding the regulation of hemp. The State argued that the regulation

was irrelevant to the offense of evading arrest and to whether Chandler was

lawfully detained. Chandler replied that:

…this is still a matter at fact. And because the jury is our

factfinders, we need to educate them on what the law is on an odor

of marijuana and that it could have been legal….I feel that it is

extremely relevant.

The State countered that even if hemp was located in Chandler’s vehicle,

…it doesn't make the detention unlawful. And, again, although

they attempted to detain the defendant, he stepped on the gas and

left. They weren't able to detain him. But even if we assume the

facts the defense's way and it wasn't really marijuana, it was CBD

or it was hemp or what have you, it's not relevant.

After these arguments, the trial court sustained the State’s objection “based on

what the charge is….”

On appeal, Chandler contends that the State proposed an incorrect

assumption at trial that Chandler had a motive to evade arrest because he had

marijuana in his vehicle. The State disputes this. Regardless, Chandler was

Chandler v. State Page 4 charged with evading arrest or detention, not possession of marijuana. Motive

is not an element of evading arrest or detention. See TEX. PENAL CODE

§ 38.04(a). Thus, educating the jury on the law regarding hemp in order to

dispel an alleged motive to flee is not a proper area of inquiry on voir dire.

Accordingly, the trial court did not abuse its discretion in limiting

Chandler’s ability to conduct voir dire about the legal difference between hemp

and marijuana. Chandler’s third issue is overruled.

CONCLUSION

Having overruled each of Chandler’s issues, we affirm the trial court's

judgment.

LEE HARRIS

Justice

OPINION DELIVERED and FILED: August 20, 2026

Before Chief Justice Johnson,

Justice Smith, and

Justice Harris

Affirmed

Do Not Publish

CR25

Chandler v. State Page 5