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08-23-00022-CR
Tex. App.
Apr 26, 2024
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Background

  • David Anthony Chapa was on community supervision (probation) after pleading guilty to unauthorized use of a vehicle in 2017.
  • The State alleged Chapa violated supervision conditions by committing a new unauthorized use of motor vehicle offense in February 2022 and failing to pay required fees.
  • The incident involved Chapa taking a truck belonging to John Hardwick without explicit authorization; his grandmother (a caregiver for Hardwick) claimed Chapa was helping her work due to her injury.
  • Chapa claimed he was working as a caregiver and believed use of the truck was permitted as part of that role.
  • After a hearing, the trial court found the allegations of unpaid fees untrue but found true the new offense allegation, revoked Chapa’s supervision, and sentenced him to eight years’ confinement.
  • On appeal, Chapa challenged only the sufficiency of the evidence that he lacked authorization to use the vehicle.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence for unauthorized use Chapa argued evidence did not show he lacked authority or was acting outside employment State claimed Chapa lacked consent to use vehicle Court found evidence sufficient to show lack of consent and misuse of vehicle

Key Cases Cited

  • Bryant v. State, 391 S.W.3d 86 (Tex. Crim. App. 2012) (standard for reviewing revocation of community supervision is abuse of discretion)
  • Rickels v. State, 202 S.W.3d 759 (Tex. Crim. App. 2006) (burden of proof on the State in revocation proceedings is preponderance of the evidence)
  • Hacker v. State, 389 S.W.3d 860 (Tex. Crim. App. 2013) (trial court may revoke supervision if any one alleged violation is supported by sufficient evidence)
  • Reasor v. State, 281 S.W.3d 129 (Tex. App.—San Antonio 2008) (all reasonable inferences are made in favor of trial court’s ruling upon appeal of revocation)
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Case Details

Case Name: David Anthony Chapa v. the State of Texas
Court Name: Court of Appeals of Texas
Date Published: Apr 26, 2024
Citation: 08-23-00022-CR
Docket Number: 08-23-00022-CR
Court Abbreviation: Tex. App.
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    David Anthony Chapa v. the State of Texas, 08-23-00022-CR