Jones, Ex Parte Richard Dewayne, 2014 Tex. Crim. App. LEXIS 763

The Court addresses whether an amendment to the evading-arrest statute (SB 1416) violated the Texas Constitution's single-subject rule.
SB 1416 amended Penal Code sections to create a tire-deflation device offense and to elevate penalties for evading arrest with a vehicle, with five enacted sections and an effective date of September 1, 2011.
The Legislature's title and enactment covered offenses related to tire deflation devices and evading arrest; the enacted provisions relate to motor-vehicle offenses and public safety.
Jones sought pretrial habeas relief alleging the amendment violated Section 35(a) by lacking a single subject; the trial court denied relief and the court of appeals affirmed.
The court reviews whether the provisions share a single subject and mutual connection, despite some diversity of topics, and whether the caption/title considerations affect validity.
The Court ultimately holds that SB 1416 does not violate the single-subject rule and affirms the lower court rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does SB 1416 violate the single-subject rule?	Jones argues log-rolling and lack of germane relationship to a single subject.	The State argues provisions relate to motor-vehicle offenses and share a mutual connection.	No single-subject violation; SB 1416 has a single subject.

LeCroy v. Hanlon, 713 S.W.2d 335 (Tex. 1986) (single-subject test permits diverse provisions with mutual connection)
Robinson v. Hill, 507 S.W.2d 521 (Tex. 1974) (courts presume validity; title considerations limited post-amendment)
Ex parte Jimenez, 317 S.W.2d 189 (Tex. 1958) (liberal construction of single-subject test)
Dellinger v. State, 28 S.W.2d 537 (Tex. Crim. App. 1930) (liberal unity-of-subject approach to uphold statute)