Deloach, Allen Maroyd, PD-0283-15

On April 2, 2012, Deputy Chris McMillian (in an unmarked vehicle with red/blue lights, wearing a badge and gun but not uniform) followed a vehicle in which Allen DeLoach was a passenger; McMillian had a warrant for DeLoach's arrest.
Both vehicles stopped in a car dealership parking lot; McMillian testified he activated his lights, called DeLoach by name, and told him to stop.
DeLoach looked toward McMillian, exited the vehicle, and ran into nearby woods; the driver (Ken Cornwell) testified he had told DeLoach a police vehicle was behind them and that DeLoach then left for the woods.
At bench trial the court convicted DeLoach under Tex. Penal Code § 38.04(b)(1) (evading arrest with prior) and assessed 10 years’ imprisonment after finding prior convictions that enhanced punishment.
The Third Court of Appeals affirmed, holding a rational factfinder could infer DeLoach knew McMillian was a peace officer attempting to detain him.

Issue	Plaintiff's Argument (State)	Defendant's Argument (DeLoach)	Held
Sufficiency: Did evidence prove DeLoach intentionally fled?	Evidence (testimony that DeLoach left vehicle and ran) supports intentional flight.	Insists evidence is at most a "modicum" and does not establish intentional flight beyond reasonable doubt.	Held sufficient — trial court could infer intentional flight.
Knowledge: Did DeLoach know the person was a peace officer?	Lights, deputy’s badge/gun, driver’s statement and deputy calling his name support knowledge.	Argues no proof DeLoach actually heard the driver or the deputy, or saw the badge/gun; facts were assumed.	Held sufficient — factfinder could reasonably conclude DeLoach knew.
Lawful attempt to arrest/detain: Was the officer lawfully attempting to arrest or detain?	Deputy testified he had an arrest warrant, giving lawful authority.	Contends there was no evidence DeLoach knew the deputy intended to detain him rather than the driver.	Held sufficient — deputy’s warrant + commands supported lawful attempt.
Overall Jackson review: Should conviction be reversed for insufficient evidence under Jackson?	Argues Jackson standard satisfied when viewed in light most favorable to verdict.	Argues Jackson requires reversal when only a "modicum" of evidence or inferences are speculative.	Held conviction stands; appellate court applied Jackson and found evidence sufficient.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of the evidence)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (appellate sufficiency standard guidance)
Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2007) (insufficient evidence principles)
Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (reviewing evidentiary support for verdict)
State v. Garcia-Cantu, 253 S.W.3d 236 (Tex. Crim. App. 2008) (use of emergency lights as a show of authority)