Anthony David Teague v. State, 06-14-00053-CR

Appellant Anthony David Teague was convicted by a jury of stalking (Tex. Penal Code § 42.072), pleaded true to an enhancement, and received 20 years’ confinement and a $10,000 fine.
Victim RK met Teague in a small, intensive graduate program; Teague pressured for a romantic/sexual relationship, which she repeatedly rejected.
After RK ended the relationship, Teague repeatedly contacted her by texts, calls, Facebook posts (including insults and veiled threats), showed up at locations she frequented, left items on her car, and attempted unwanted physical contact.
RK and roommates feared him, changed routines, had friends accompany her, and called police multiple times; SMU issued a no-contact and criminal trespass warnings.
Two appellate issues: (1) whether the trial court should have conducted an informal competency inquiry sua sponte; (2) whether the evidence was legally sufficient to support the stalking conviction.

Issue	Plaintiff's Argument (Teague)	Defendant's Argument (State)	Held
Whether trial court erred by failing to conduct an informal competency inquiry sua sponte	Trial court should have inquired into competency based on historical letters/incidents and other record material suggesting mental instability	No suggestion at trial that Teague was incompetent; counsel did not request inquiry and record showed competency exams found him competent; no contemporaneous evidence that he could not consult with counsel or understand proceedings	Trial court did not abuse discretion; no informal inquiry required
Whether evidence was legally sufficient to convict for stalking	Evidence insufficient because there was no history of violence, no weapons, no explicit threats of bodily injury	Statute punishes repeated conduct knowingly likely to be regarded as threatening and that caused fear; threats, disclosures, following, unwanted contact, and victim’s reasonable fear suffice	Evidence legally sufficient to support stalking conviction

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for appellate sufficiency review)
Fluellen v. State, 443 S.W.3d 365 (Tex. App.—Texarkana 2014) (no informal competency inquiry required where record contains no evidence defendant could not participate in proceedings)
Jackson v. Virginia, 443 U.S. 307 (1979) (legal-sufficiency standard; evidence viewed in light most favorable to verdict)
Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1991) (abuse of discretion standard for trial-court decisions)
Ploeger v. State, 189 S.W.3d 799 (Tex. App.—Houston [1st Dist.] 2006) (stalking conviction upheld where repeated unwanted gifts, following, and victim’s fear established sufficiency)
Pomier v. State, 326 S.W.3d 373 (Tex. App.—Houston [14th Dist.] 2010) (example of sufficiency analysis under stalking statute)
Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (when record shows defendant’s mental illness prevents rational engagement with counsel or understanding proceedings, competency inquiry required)