Arthur Robison v. State, 06-17-00082-CR

On Jan. 28, 2015, Carrollton officer Heather Brun responded to a 9-1-1 report of a suspicious person; caller Retha Campos said a white male in his late 20s had knocked on her door and left in a silver double-cab pickup toward Josey Lane.
Brun arrived ~2 minutes later, found a silver pickup with engine running and headlights on near the caller’s home, and observed a white male in a nearby greenbelt with a flashlight.
Brun smelled alcohol on the man, identified him as Arthur Robison, and questioned him; Robison said he had been at a friend’s house and denied drinking, but had difficulty giving directions and admitted searching for a broken side-view mirror he believed came off when he hit another truck.
Investigating the area, Brun found damaged bushes, trees, a knocked-down road sign, and pieces of a mirror in the median consistent with Robison’s truck; officers later found a prescription hydrocodone bottle and blood showed marijuana and cocaine.
Robison was arrested for DWI (third or more) and convicted by a jury; he appealed arguing (1) insufficient evidence he was operating the vehicle and (2) the $100 emergency-medical-services (EMS/trauma) court cost is facially unconstitutional. The court affirms conviction (modified costs).

Issue	Plaintiff's Argument (Robison)	Defendant's Argument (State)	Held
Whether evidence was legally sufficient to prove Robison "operated" the vehicle	Robison contends his admission he drove, without independent corroboration, fails the corpus delicti rule; no officer saw him driving	The State argues physical and circumstantial evidence (truck idling, engine on, mirror parts, recent damage near route, temporal proximity to call, eyewitness description) corroborate that he had operated the truck	Court: Evidence (admission + independent corroboration) sufficed to prove operation; point overruled
Whether the $100 EMS/trauma court cost under Art. 102.0185(a) is facially constitutional	Robison argues the fee is not tied to a legitimate criminal-justice purpose and is therefore a facially unconstitutional tax	The State argued the statutory definitions could encompass legitimate trauma/EMS costs tied to intoxication victims, making the fee a criminal-justice purpose	Court: Fee is facially unconstitutional; trial-court judgment modified to remove the $100 EMS cost (court costs reduced from $484 to $384)

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for legal-sufficiency review under Jackson)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (reasonable-doubt sufficiency standard)
Hacker v. State, 389 S.W.3d 860 (Tex. Crim. App. 2013) (confession alone insufficient absent independent corpus delicti corroboration)
Kirsh v. State, 357 S.W.3d 645 (Tex. Crim. App. 2012) (operating analyzed by totality of circumstances)
Denton v. State, 911 S.W.2d 388 (Tex. Crim. App. 1995) (broad interpretation of "operating")
Salinas v. State, 523 S.W.3d 103 (Tex. Crim. App. 2017) (construing fees and holding certain allocations not a legitimate criminal-justice purpose)
Peraza v. State, 467 S.W.3d 508 (Tex. Crim. App. 2015) (burden and framework for facial challenges to court-cost statutes)