Crawford v. State, 355 S.W.3d 193

Crawford was convicted by bench trial of the third‑degree felony evading arrest or detention in a vehicle, with a prior conviction for the same offense, and accordingly received three years’ imprisonment, probated for three years, and a $1,000 fine.
After conviction, Crawford discharged trial counsel and retained new counsel who moved for a new trial citing ineffective assistance; the trial court denied the motion.
Officer McGrew observed Crawford’s vehicle’s front-seat passenger looking toward the patrol car and noted the vehicle’s insurance policy had lapsed over forty‑five days prior via MDT; based on that, he attempted to stop Crawford.
Crawford fled the scene, struck the patrol car with his vehicle, and was ultimately pulled from the car; insurance information confirmed the policy had expired in August 2009.
The State challenged Crawford’s ineffective assistance claim at the motion-for-new-trial stage; the court found no merit in the claims and Crawford appealed on sufficiency of the evidence and ineffective assistance grounds.
The court on rehearing affirmed the original judgment, holding the evidence sufficient to support the conviction and that counsel’s conduct did not meet Strickland’s standards under the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence is legally sufficient to support evading arrest	Crawford claims insufficiency	State contends sufficient evidence	Evidence sufficient to support conviction
Whether the detention was lawful	Crawford argues no lawful basis	State asserts reasonable suspicion supported stop	Detention lawful; MDT data supported reasonable suspicion
Whether trial counsel was ineffective for not filing suppression	Ineffective assistance due to failure to suppress	No merit; suppression motion would not change outcome	No ineffectiveness; outcome unlikely to differ
Whether trial counsel was ineffective for not calling Crawford's brother	Witness would have aided defense	Witness unavailable or cumulative testimony	No proof that testimony would have benefitted defense; not ineffective assistance

Jackson v. Virginia, 443 U.S. 307 (1980) (standard for legal sufficiency of evidence)
In re Winship, 397 U.S. 358 (1970) (proof beyond a reasonable doubt standard applied to evidence)
Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (appellate review defers to fact finder on credibility)
Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (standard for reviewing evidentiary sufficiency)
Guillory v. State, 99 S.W.3d 735 (Tex. App.—Houston [1st Dist.] 2003) (lawfulness of detention and reasonable suspicion)