Joseph Leo Strehl, III v. State, 06-15-00117-CR

Appellant Joseph Leo Strehl III was indicted for DWI (third or more) based on an August 25, 2014 arrest; indictment alleged multiple prior DWI convictions to elevate the offense to felony.
On June 16, 2015 the trial court denied motions to dismiss/quash challenges to jurisdictional/enhancement paragraphs and denied a motion to suppress; Strehl pled not guilty and proceeded to trial.
Police stopped Strehl after dispatch relayed a 911 caller’s report of a possibly intoxicated man who entered a white Peterbilt and drove toward Lowe’s; the officer did not speak with the caller before stopping the truck, did not know the caller’s identity, and observed no traffic violation prior to the stop.
After the stop, Strehl performed poorly on field sobriety tests, was arrested for DWI, and a warrant was obtained for a blood draw.
The State introduced a certified judgment (State’s Exhibit Six) purporting to be a 2002 DWI conviction for Strehl; the judgment contained the name only — no fingerprints, photo, or other identifying data — and the State’s fingerprint expert testified he could not connect that judgment to Strehl.
Trial court admitted the 911 recording and Exhibit Six over Strehl’s hearsay/identity objections; Strehl moved for directed verdict on sufficiency of the prior-conviction proof and preserved suppression and evidentiary claims on appeal.

Issue	Plaintiff's Argument (Strehl)	Defendant's Argument (State)	Held (trial-court rulings preserved for appeal)
Admissibility and sufficiency to prove prior conviction for enhancement	Exhibit Six (2002 judgment) is legally insufficient to prove Strehl’s prior DWI because it contains only a name and no fingerprints, photo, or other independent identity evidence	Certified judgment is admissible; offered fingerprint expert as sponsoring witness for prior-conviction exhibits	Trial court overruled objection and admitted Exhibit Six; directed-verdict motion denied (preserved for appellate review)
Validity of traffic stop / reasonable suspicion for investigatory detention	Officer lacked reasonable suspicion: he observed no traffic violation, did not speak to 911 caller, did not know caller’s identity, and caller did not identify Strehl as the person observed	Officer relied on citizen report relayed by dispatch and stopped vehicle for public safety and possible DWI	Trial court denied motion to suppress; suppression ruling preserved for appeal

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-evidence standard)
Beck v. State, 719 S.W.2d 205 (penalizes relying solely on judgments without independent identity evidence)
Vessels v. State, 432 S.W.2d 108 (prior-conviction proof methods)
Littles v. State, 726 S.W.2d 26 (penitentiary packet/photo may suffice to identify prior offender)
Cruz v. State, 346 S.W.3d 601 (certified judgment without booking packet or other identity proof is insufficient for enhancement)
Zimmer v. State, 989 S.W.2d 48 (booking slip/fingerprint without link to judgment insufficient to prove identity)
Griffin v. State, 866 S.W.2d 754 (same principle: name coincidence is insufficient absent independent identity evidence)
Martinez v. State, 348 S.W.3d 919 (totality-of-circumstances and reliability of anonymous 911 tips for reasonable suspicion)
Carmouche v. State, 10 S.W.3d 323 (standard of review for mixed questions in suppression rulings)
Hubert v. State, 312 S.W.3d 554 (deference to trial court fact findings on suppression; appellate review framework)