Baggett v. State, 342 S.W.3d 172

Baggett appealing a conviction for DWI enhanced to a 25-year sentence after an open guilty plea.
Issue concerns sufficiency of evidence to support the guilty plea under Article 1.15 of the Texas Code of Criminal Procedure.
State conceded no written stipulation of evidence and there were no written plea papers in the record.
Record shows only the plea exchange where Baggett pled guilty and later testified she was not intoxicated; no independent evidence of guilt beyond the plea.
Court determined there was no independent evidence to substantiate Baggett's guilt and reversed for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence to support Baggett's guilty plea under Article 1.15?	Baggett lacked independent evidence beyond the plea.	Plea alone constitutes admission; no need for additional evidence.	Insufficient evidence; remand for new trial.

Menefee v. State, 287 S.W.3d 9 (Tex.Crim.App.2009) (judicial confession must embrace every element)
Ex parte Williams, 703 S.W.2d 674 (Tex.Crim.App.1986) (plea alone not a judicial confession)
Moon v. State, 572 S.W.2d 681 (Tex.Crim.App.1978) (plea must be supported by evidence)
Spivey v. State, 143 S.W.2d 386 (Tex.Crim.App.1940) (state must introduce evidence when plea entered)
Bender v. State, 758 S.W.2d 278 (Tex.Crim.App.1988) (not a federal constitutional violation when insufficient evidence)
Ford v. State, 73 S.W.3d 923 (Tex.Crim.App.2002) (harm analysis for non-constitutional error)
Morales v. State, 32 S.W.3d 862 (Tex.Crim.App.2000) (substantial rights burden in harm analysis)
Haley v. State, 173 S.W.3d 510 (Tex.Crim.App.2005) (Rule 44.2(b) harmless error standard)
Johnson v. State, 967 S.W.2d 410 (Tex.Crim.App.1998) (harm analysis framework for non-structural errors)
Mendez v. State, 138 S.W.3d 334 (Tex.Crim.App.2004) (structural vs non-structural error distinction clarified)