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Judge Boyd awards federal-custody credit, denies treatment-credit claim in Beltrán case
Summary
Judge Stephanie Boyd ruled that Christopher Daniel Beltrán will receive credit for federal custody beginning April 10, 2023, but denied credit for time claimed as successful completion of a TDCJ treatment program after finding the defendant absconded from a halfway house.
Judge Stephanie Boyd, presiding over the 187th District Court, ruled on credit for custody and treatment in the case State v. Christopher Daniel Beltrán.
The court found that Beltrán is entitled to credit for time in federal custody beginning April 10, 2023, because a drug-court warrant had been issued March 24, 2023, and he was in federal custody during the pendency of the case. "The court is gonna find that he's entitled to time, beginning 04/10/2023," Boyd said, directing the clerks to record that credit.
The hearing also addressed whether Beltrán should receive credit for time spent in a substance-abuse treatment program run by the Texas Department of Criminal Justice (TDCJ) or for aftercare/residential facilities. The defense argued Beltrán had "successfully completed the treatment program" at SAFE P (described in the hearing as part of the TDCJ system). The State disputed that aftercare or halfway-house placements should automatically qualify for credit under the statute cited in court.
Judge Boyd reviewed the statutory language discussed at the hearing (quoted in court as "42 0 3, section 2 a 2" and references to the Texas Department of Criminal Justice and the Government Code) and the parties' evidence about program structure. After noting the law's ambiguity as presented, Boyd found no evidence Beltrán had successfully completed the inpatient portion in a way that entitled him to credit: the record indicated Beltrán was ordered to a halfway house as part of continuing treatment and that he absconded from that placement. "So the court is not gonna give you credit for safety time," Boyd said, explaining the court's conclusion that successful completion had not been shown.
The court therefore ordered clerks to apply federal-custody credit starting 04/10/2023 and declined to grant credit for the contested treatment/aftercare period.
The judge instructed counsel to ensure the clerk's entry reflected the federal dates; no further relief on the treatment-credit question was granted at that hearing.
