Joshua Jamal Jenkins v. State, 454 S.W.3d 712

At 12:30 a.m. on Dec. 23, 2012, an Austin police sergeant observed six to eight people around a Nissan Altima at an apartment-complex entrance; when his marked patrol car turned onto the street the group dispersed and the Altima drove off.
The sergeant followed; during the pursuit he observed multiple traffic violations (speeding ~80 mph in a 35 mph zone, passing in a bike lane, crossing double yellow lines, running stop signs and red lights).
The sergeant activated lights and siren and declared a pursuit; other units and a helicopter joined; the Altima later stopped and Jenkins, the sole occupant/operator, was arrested.
Jenkins was tried and convicted by a jury of evading arrest with a vehicle under Tex. Penal Code § 38.04; he agreed to an assessed punishment of 10 years’ imprisonment.
On appeal Jenkins raised (1) insufficiency of the evidence as to whether officers were lawfully attempting to arrest or detain him, and (2) a challenge to the constitutionality of SB 1416 under Texas’s single-subject rule.
The Court of Appeals affirmed the conviction, rejecting both issues.

Issue	Plaintiff's Argument (Jenkins)	Defendant's Argument (State)	Held
Sufficiency of evidence to prove lawful stop/detention	Sgt. White had no lawful basis to detain when he first observed the car leaving; later observations cannot cure that initial illegality, so evading conviction fails	Although initial observation lacked probable cause, subsequent traffic violations observed in plain view provided an objective, lawful basis to stop and detain Jenkins	Evidence sufficient: jury could find Jenkins intentionally fled from officers lawfully attempting to detain/arrest him based on later-observed traffic violations
Constitutionality of SB 1416 (single-subject rule)	SB 1416 violates Texas Constitution’s single-subject rule, so the statute increasing penalty is invalid	Court of Criminal Appeals has upheld SB 1416; Ex parte Jones concluded the statute is constitutional	Rejected Jenkins’s challenge; Ex parte Jones controls and the legislative change stands

Jackson v. Virginia, 443 U.S. 307 (established standard for sufficiency review under due process)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (articulates Texas application of Jackson standard)
Temple v. State, 390 S.W.3d 341 (Tex. Crim. App. 2013) (jury as factfinder on witness credibility and resolving conflicts)
Garcia v. State, 43 S.W.3d 527 (Tex. Crim. App. 2001) (State must show objective basis for stop; subjective intent irrelevant)
Wehrenberg v. State, 416 S.W.3d 458 (Tex. Crim. App. 2013) (evidence discovered after prior unlawful conduct may be admissible if lawful basis existed independent of the illegal act)
Segura v. United States, 468 U.S. 796 (discusses independent-source doctrine)
Ex parte Jones, 440 S.W.3d 628 (Tex. Crim. App.) (upheld constitutionality of SB 1416)