John Mark Bass v. State, 09-17-00306-CR

Appellant John Mark Bass pleaded guilty to third-degree felony assault against a family member and pled true to four enhancement paragraphs; the trial court sentenced him to 30 years' imprisonment.
Victim A.B. testified she was slapped twice by Bass during an August 30, 2016, altercation, placed a 9-1-1 call, and Bass was in her vehicle when she called; 9-1-1 audio and injury photos were admitted.
Deputy Joshua Brown encountered Bass driving in the neighborhood, activated lights and siren, and testified that Bass accelerated, evaded by turning through streets and abandoning the vehicle in a wooded lot; Bass fled and was captured after a K-9 search.
On direct examination Deputy Brown estimated Bass’s speed ("somewhere around 60" or "60 and 65") based on his observations and his patrol video; defense counsel objected as speculative and the trial court overruled.
The State admitted multiple prior-incident witnesses and Bass stipulated to numerous prior convictions introduced at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of officer’s speed estimate at punishment	Brown had personal knowledge and could testify to speed from observation/video	Bass argued Brown lacked sufficient personal knowledge and testimony was speculative	Court held admission was within trial court's discretion; no abuse and no substantial-rights harm

Tillman v. State, 354 S.W.3d 425 (Tex. Crim. App. 2011) (abuse-of-discretion standard for evidentiary rulings)
Martinez v. State, 327 S.W.3d 727 (Tex. Crim. App. 2010) (same)
Coble v. State, 330 S.W.3d 253 (Tex. Crim. App. 2010) (erroneous evidentiary rulings generally non-constitutional)
Walters v. State, 247 S.W.3d 204 (Tex. Crim. App. 2007) (prejudice standard for non-constitutional error)
King v. State, 953 S.W.2d 266 (Tex. Crim. App. 1997) (substantial-rights analysis: error requires substantial injurious effect on outcome)