Matthew Laird Shaffer v. the State of Texas
12-21-00051-CR
| Tex. App. | Apr 14, 2022Background
- Shaffer was indicted for felony evading arrest with a vehicle (offense dated on or about Jan. 8, 2020); he pled not guilty and was tried by jury.
- Officers Holland (bicycle unit, in uniform) and Main (in uniform in an unmarked unit) were conducting a traffic stop when Holland saw Shaffer drive past a marked patrol unit with lights flashing, made eye contact, knocked on Shaffer’s window and loudly commanded him to stop.
- Shaffer ran the red light, turned off his headlights, drove erratically, and ultimately parked in a residential driveway where Main arrested him; drug paraphernalia was found and Main testified Shaffer said he knew he was running from police.
- Body‑worn camera footage from both officers was played at trial (some audio heavily redacted for punishment-related matters).
- The jury found Shaffer guilty of evading in a vehicle, found a prior felony enhancement true, and imposed a 20‑year sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that Shaffer knew person attempting to detain/arrest him was a peace officer | State: evidence of marked patrol vehicle with flashing lights, Holland in uniform, Holland’s commands, bodycam footage, and Main’s testimony (including admissions by Shaffer) support inference of knowledge and intent to flee | Shaffer: it was dark; Holland did not sufficiently display authority (flashlight, atypical bike uniform, no verbal ID), some incriminating statements occurred after Main told him he’d run, so knowledge is speculative | Court: Affirmed — viewing evidence in the light most favorable to the verdict, the jury could rationally infer Shaffer knew officers were attempting to detain him and intentionally fled |
| Trial court’s assessment of court costs (county specialty court account and courthouse security fund) | State: statutory redesignation and the Local Consolidated Fee on Conviction of Felony (effective for offenses committed on/after Jan. 1, 2020) make the $105 allocation (including $25 county specialty court and $10 courthouse security) applicable to Shaffer’s offense | Shaffer: county specialty court account does not apply to his offense; courthouse security fee should be $5 not $10 | Court: Affirmed — statutes enacted/revised in 2019 apply to offenses after Jan. 1, 2020 (Shaffer’s offense date), so assessed fees were proper |
Key Cases Cited
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for reviewing sufficiency of the evidence and deference to jury credibility findings)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence and reasonable inferences in sufficiency review)
- Smith v. State, 483 S.W.3d 648 (Tex. App. — Houston [14th Dist.] 2015) (intent to evade may be inferred from driving behavior and pursuit circumstances)
- State v. Walker, 195 S.W.3d 293 (Tex. App. — Tyler 2006) (same—factors for inferring intent from conduct during pursuit)
- Duvall v. State, 367 S.W.3d 509 (Tex. App. — Texarkana 2012) (evading conviction reversed where there was no evidence officer displayed authority)
- Alejos v. State, 555 S.W.2d 444 (Tex. Crim. App. 1977) (purposes of evading statute and public policy discouraging flight)
- Redwine v. State, 305 S.W.3d 360 (Tex. App. — Houston [14th Dist.] 2010) (discussing show of authority and encouragement to yield to law enforcement)