Mercedez Leshion Jones v. State, 373 S.W.3d 790

Jones appeals a conviction for aggravated robbery after pleading guilty and receiving a 15-year sentence.
Indictment alleged aggravated robbery with a deadly weapon (firearm) during theft of Noah Hunter’s property, with intent to obtain/control it.
Jones pled guilty in writing on April 27, 2011, waiving jury, confrontation, and self-incrimination rights; she also signed a confession and stipulation.
Plea was in open court before Judge Duggan; sentencing hearing before Judge Keel; PSI reviewed but not admitted.
Article 1.15 requires evidence beyond the plea to substantiate guilt; evidence may be in various forms and can come from sentencing testimony.
The State presented testimony at sentencing describing the events; the court found Jones guilty and sentenced her to 15 years, and the court’s ruling is reviewed for sufficiency of evidence to substantiate the plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence to substantiate the guilty plea under Article 1.15.	Jones argues the State failed to present independent evidence of guilt beyond the plea.	State contends the sentencing evidence was sufficient to substantiate the plea.	Yes; the evidence at sentencing substantiated the guilty plea.

Menefee v. State, 287 S.W.3d 9 (Tex. Crim. App. 2009) (art. 1.15 evidence may come from various forms to sustain a guilty plea)
Staggs v. State, 314 S.W.3d 155 (Tex. App.—Houston [1st Dist.] 2010) (need not prove guilt beyond reasonable doubt for 1.15 substantiation)
Palacios v. State, 942 S.W.2d 748 (Tex. App.—Houston [14th Dist.] 1997) (written confession approved by court can substantiate plea)
Rexford v. State, 818 S.W.2d 494 (Tex. App.—Houston [1st Dist.] 1991) (confession may substantiate plea if properly considered)
Adames v. State, 353 S.W.3d 854 (Tex. Crim. App. 2011) (law of parties may apply to 1.15 substantiation)
Montoya v. State, 810 S.W.2d 160 (Tex. Crim. App. 1989) (law of parties applicability to 1.15 substantiation)