Bobby Lynn Keene v. State, 10-15-00389-CR

Appellant Bobby Lynn Keene was convicted of (1) aggravated assault on a public servant (enhanced) and (2) evading arrest or detention with a vehicle (enhanced); concurrent sentences of 40 and 20 years were imposed. Two separate judgments were entered.
Officers pursued Keene after finding him in a pickup on the roadside; he fled a multi-county chase exceeding 30 miles, ran over spikes, and was stopped after a PIT/bump maneuver.
Deputies Steven Strahl, Kenneth Witt, and Chris Eubank approached Keene’s vehicle with weapons drawn; Keene pulled a large, heavy homemade knife (about 14+ inches, ~31 oz.) through a broken driver-side window and made a threatening motion.
All three deputies jumped back; deputies testified they felt threatened and believed the threat was imminent. Video showed their uniform reaction.
The State introduced the knife into evidence and, during punishment, produced certified documents (complaint, stipulation, judgment, etc.) to prove a prior deadly-conduct conviction; some documents included Keene’s name, DOB, and SSN.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aggravated assault on a public servant (imminent threat)	State: deputies were in immediate danger when Keene brandished a large, deadly knife and made a motion toward them.	Keene: evidence insufficient because only Deputy Eubank (not named in indictment) was close enough to be threatened; others were not imminently threatened.	Affirmed — evidence sufficient; jury could infer an imminent threat to the named officers from the knife and deputies’ reaction.
Sufficiency of evidence to prove prior deadly-conduct conviction for enhancement	State: certified court records and witness testimony linked the documents to Keene and showed a prior conviction.	Keene: identifying information was largely on a motion to revoke (dismissed); lack of fingerprints and some documentary gaps fail to link him to the prior.	Affirmed — totality of documentary and testimonial evidence was sufficient to prove the prior conviction and link it to Keene.

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing legal sufficiency of evidence)
Hooper v. State, 214 S.W.3d 9 (circumstantial evidence can suffice and cumulative inference standard)
Lucio v. State, 351 S.W.3d 878 (discusses sufficiency review principles)
Conner v. State, 67 S.W.3d 192 (review of "all evidence" includes properly and improperly admitted evidence)
Chambers v. State, 805 S.W.2d 459 (factfinder entitled to judge witness credibility)
Olivas v. State, 203 S.W.3d 341 (defines threatening conduct and risk that places another in fear)
Devine v. State, 786 S.W.2d 268 ("imminent" requires present, not future, threat)
Flowers v. State, 220 S.W.3d 919 (proving prior conviction for enhancement: existence and linkage elements; totality of evidence test)