Kanayo Eugene Ubesie, Jr. v. State, 379 S.W.3d 371

Ubesie was convicted of DWI under Texas Penal Code §49.04(a) and sentenced to 180 days in Navarro County Jail.
Evidence showed Ubesie and Migl consumed Xanax and codeine cough syrup before traveling toward Houston.
They stopped for a flat tire; a lug-nut security adaptor was missing, prompting them to seek help.
Trooper Taylor observed both men with slurred speech, unsteady gait, and near-closed eyes at a Citgo station.
Taylor noted Ubesie was the driver and that he drove to the gas station after the 911 call was made.
The State argued there was a temporal link: driving occurred around 8:23 pm and police encountered them at 8:47 pm, with intoxication observed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was a temporal link between driving and intoxication	Ubesie contends no temporal link was shown	State argues driving occurred while intoxicated with corroborating observations	Temporal link established; evidence supports intoxication during driving

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of evidence)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson standard applied; no higher burden for sufficiency)
Kuciemba v. State, 310 S.W.3d 460 (Tex. Crim. App. 2010) (necessity of temporal linkage between intoxication and driving)
Stoutner v. State, 36 S.W.3d 716 (Tex. App.—Houston [1st Dist.] 2001) (temporal relation required to connect intoxication to driving)
Weaver v. State, 721 S.W.2d 495 (Tex. App.—Houston [1st Dist.] 1986) (driving-related intoxication must be shown)
Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (circumstantial evidence admissible to prove intoxication)
Zavala v. State, 89 S.W.3d 134 (Tex. App.—Corpus Christi 2002) (time of driving need not be exact; must contextualize intoxication)
Kennedy v. State, 797 S.W.2d 695 (Tex. App.—Houston [1st Dist.] 1990) (limits on how timing informs relationship between driving and intoxication)