Michael Hurley Young v. the State of Texas, 04-24-00534-CR

Michael Hurley Young was convicted by a jury in Guadalupe County, Texas, for driving while intoxicated (DWI) with a blood alcohol concentration (BAC) of 0.15 or more, a Class A misdemeanor.
The incident involved Young’s vehicle flipping over, after which he was found at the scene by bystanders, exhibiting signs of intoxication such as slurred speech and staggering.
Law enforcement arrived; Young admitted to being the driver and to consuming alcohol, and later refused voluntary blood or breath tests, resulting in a compelled blood draw showing a BAC of 0.169.
At trial, key portions of body camera footage from officers were missing or destroyed, though dashcam footage was preserved and admitted.
Young appealed the conviction, raising issues about the admissibility of officers’ testimony regarding destroyed footage, sufficiency of evidence, and use of his own statements when recorded evidence was missing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of testimony on destroyed body camera footage	Violates Confrontation Clause	Objection not preserved at trial; thus, argument unpreserved	Overruled; not preserved
Sufficiency of evidence for conviction	No direct evidence he was driving; testimony unreliable without video	Circumstantial evidence and admissions sufficient	Overruled; evidence legally sufficient
Admission of statements without electronic recording	Violated Texas Code Crim. Proc. Art. 38.22 (custodial interrogation)	Objection not preserved	Overruled; not preserved

Paredes v. State, 129 S.W.3d 530 (Tex. Crim. App. 2004) (Confrontation Clause objections must be made at trial to be reviewed on appeal)
Kuciemba v. State, 310 S.W.3d 460 (Tex. Crim. App. 2010) (circumstantial evidence reviewed under same sufficiency standard as direct evidence)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (cumulative force of circumstantial evidence can support conviction)