Donny Joe Curry v. State, 06-14-00141-CR

Officer Manrique stopped Appellant for traffic violations (swerving, broken taillight, homemade paper license plate/inspection/registration) on Aug. 26, 2013.
Appellant told officers he had no driver’s license or insurance, gave only his first name (“Donny”), refused to give his last name, and claimed to be a sovereign citizen.
Appellant handed officers paperwork asserting exemption from state law but provided no identifying information; identifying paperwork was later found in the vehicle after arrest.
Backup officers (Lieutenant Pehl and Sergeant Scott) arrived; Pehl ordered Appellant to identify himself, Appellant refused, resisted extraction from the vehicle, and was tased twice and arrested.
Appellant was convicted in county court of three Class C misdemeanors (Failure to Identify; Failure to Maintain Financial Responsibility; No Inspection) and fined $250 on each count; he appealed raising sufficiency of evidence for failure-to-identify and alleged sentencing/clerical errors.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Appellant)	Held
Sufficiency of evidence for Failure to Identify (Tex. Penal Code §38.02)	Evidence shows Appellant was lawfully detained, officers requested his name, and he intentionally refused to give his full name or identification.	Appellant contends there was no lawful detention or otherwise challenges sufficiency.	Conviction affirmed: detention lawful (traffic stop) and refusal was intentional — evidence sufficient.
Sentencing / Punishment range & clerical error in judgment	Sentences ($250 fines each) are within the Class C misdemeanor statutory range; handwritten jail notation was a clerical error that should be reformed.	Appellant argues punishment outside applicable range due to the post-judgment handwritten jail time.	Held that fines were lawful; appellate court may reform judgment to correct clerical error (delete improper jail notation).

Jackson v. Virginia, 443 U.S. 307 (sufficiency review standard)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (appellate review of legal sufficiency)
Montgomery v. State, 369 S.W.3d 188 (Tex. Crim. App. 2012) (deference to jury on credibility/inferences)
Whren v. United States, 517 U.S. 806 (traffic stop reasonable if supported by objective basis)
Arizona v. Johnson, 555 U.S. 323 (passengers detained during traffic stop)
Navarette v. California, 134 S. Ct. 1683 (reasonable suspicion standard for stops)
Hemphill v. State, 505 S.W.2d 560 (Tex. Crim. App. 1974) (intent as fact question)
Mizell v. State, 119 S.W.3d 804 (Tex. Crim. App. 2003) (unauthorized sentence relief on appeal)
Ex parte Rich, 194 S.W.3d 508 (authority to correct illegal sentences)
Asberry v. State, 813 S.W.2d 526 (clerical errors in judgments remedied by reformation)
Overshown v. State, 329 S.W.3d 201 (Tex. App. — Houston [14th Dist.] 2010) (lawful detention in failure-to-identify context)