Brent Alan Dalton v. State
01-14-00837-CR
| Tex. App. | Sep 30, 2015Background
- Defendant Brent Alan Dalton was charged with DWI (with a prior felony enhancement); a jury found him guilty and the trial court sentenced him to 60 days in county jail.
- Deputies stopped a Chevrolet Silverado after a 911 caller reported it driving into oncoming traffic and running another driver off the road; the vehicle initially failed to comply with emergency lights and commands.
- When Dalton exited the vehicle he staggered toward an officer, displayed bloodshot eyes, slurred speech, and could not stand unassisted; officers observed similar signs later at the station and during sobriety testing.
- Dalton admitted at various times to taking prescription central nervous system depressants (and told one officer he took them 15 minutes before driving); his blood later tested positive for four CNS depressants and marijuana.
- Officers performed a drug recognition evaluation concluding Dalton had lost normal use of his mental and physical faculties due to a central nervous system depressant; Dalton initially consented to blood but later revoked consent, and police obtained a warrant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that Dalton was intoxicated while driving | State: observed driving + contemporaneous signs (staggering, slurred speech, inability to stand), admissions about drug use, DRE opinion, and blood toxicology support a rational juror's finding of intoxication while operating a vehicle | Dalton: temporal link lacking — evidence insufficient to prove he was intoxicated at the precise time he was driving; symptoms could be medical or post-arrest | Court affirmed: viewing evidence in light most favorable to verdict, sufficient evidence supported intoxication while operating the vehicle; jury credibility determinations control |
| Legality of stop based on anonymous 911 tip | State: stop lawful; anonymous tip matching make/model/license and behavior is sufficient to justify the stop | Dalton: stop unlawful because based solely on 911 report | Not reviewed on appeal (no trial objection), and State notes precedent supporting reliability of such 911 reports |
| Alternative medical explanations for observed symptoms | Dalton: symptoms could stem from medical conditions or doctor's treatment (hydrocodone) rather than intoxication | State: jury could disbelieve defendant’s self-serving statements; State not required to disprove all alternative hypotheses on sufficiency review | Rejected as grounds to overturn; inconsistencies and credibility issues for jury to resolve |
Key Cases Cited
- Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (appellate deference to jury credibility and conflicting evidence)
- Merritt v. State, 368 S.W.3d 516 (Tex. Crim. App. 2012) (standards for sufficiency review: view evidence in light most favorable to verdict)
- Kirsch v. State, 276 S.W.3d 579 (Tex. App.—Houston [1st Dist.] 2008) (refusal or failure to follow commands may indicate intoxication)
- Wyatt v. State, 23 S.W.3d 18 (Tex. Crim. App. 2000) (jury may believe some testimony and disbelieve other testimony)
- Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (anonymous 911 reports can provide reasonable suspicion for traffic stops when sufficiently detailed)