Gerald Powell v. State, 01-15-00975-CR

Police allege Gerald Powell participated in a robbery after Rukshana Ali withdrew $30,000, was confronted by two men, had her car keys taken, was pushed and fell, and her car (with the money) was driven off.
Ali identified Powell from a photo array; Powell’s fingerprints were found in the stolen car recovered in Houston.
Powell was indicted for robbery alleging he, during the course of theft and with intent to obtain/maintain control of the property, intentionally/knowingly/recklessly caused bodily injury by pushing Ali to the ground.
Powell pleaded guilty without an agreed punishment recommendation and signed a written plea that included a stipulation/judicial confession that he committed the acts alleged and that the evidence would prove the allegations beyond a reasonable doubt.
After a sentencing hearing the trial court sentenced Powell to eight years’ imprisonment; Powell appealed, arguing legal insufficiency of the evidence supporting his conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was legally sufficient to support a conviction after a guilty plea	State: Powell’s written stipulation and judicial confession, together with the indictment, supply sufficient evidence of the elements of robbery	Powell: The evidence before the court was legally insufficient to convict him of robbery	Court: Affirmed — Powell’s written stipulation that he committed the acts alleged (incorporating the indictment’s elements) was legally sufficient to support the conviction

Menefee v. State, 287 S.W.3d 9 (Tex. Crim. App. 2009) (a written/oral stipulation of evidence that embraces every element suffices to support a guilty plea)
Keller v. State, 125 S.W.3d 600 (Tex. App.—Houston [1st Dist.] 2003) (a stipulation incorporating the indictment by reference satisfies the element requirement)
McCall v. State, 113 S.W.3d 479 (Tex. App.—Houston [1st Dist.] 2003) (definition and elements of robbery)