Nathan Harris Jones v. State
14-15-00025-CR
| Tex. App. | Mar 10, 2015Background
- Nathan Jones was convicted after a bench trial of Driving While Intoxicated (Class B misdemeanor) for conduct on January 18, 2014; judge sentenced 180 days confinement probated 2 years and imposed conditions including ignition interlock.
- Officer Miranda McGee observed Jones’s vehicle straddling the center line, moving into an adjacent lane and appearing to push another car toward the bike lane; Jones allegedly cut off the other driver and failed to signal.
- McGee activated her lights and stopped Jones at about 3:17 a.m.; she detected odor of alcohol, slurred speech, and glassy eyes; Jones admitted drinking three alcoholic beverages earlier.
- McGee administered three standardized field sobriety tests: HGN (4 of 6 clues), walk-and-turn (multiple clues), and offered one-leg stand which Jones refused; Jones refused breath test at the jail.
- Appellate counsel filed an Anders brief concluding no non-frivolous appellate issues after reviewing the record, but identified two possible issues: legal sufficiency of the evidence and whether there was reasonable suspicion for the stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Legal sufficiency of evidence to convict for DWI | State: Officer testimony, FST results, and video sufficiently proved operation of a vehicle while intoxicated. | Jones: Evidence was insufficient to support guilty verdict. | Court record: Appellate counsel concludes the State met its burden and a sufficiency challenge would be frivolous. |
| 2. Reasonable suspicion for the traffic stop | State: Observed traffic violations (straddling lane, unsafe lane change, failing to signal, creating safety risk) gave objective reasonable suspicion for an investigative stop. | Jones: No reasonable suspicion existed to justify the stop. | Court record: Counsel concludes the observed traffic violations provided reasonable suspicion; suppression argument would likely fail. |
Key Cases Cited
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (legal-sufficiency standard review)
- Temple v. State, 342 S.W.3d 572 (Tex. App.—Houston [14th Dist.] 2010) (application of sufficiency standard)
- Terry v. Ohio, 392 U.S. 1 (1968) (framework for investigative stops)
- United States v. Sokolow, 490 U.S. 1 (1989) (reasonable-suspicion analysis under totality of circumstances)
- Maryland v. Wilson, 519 U.S. 408 (1997) (reasonableness standard for brief detentions)
- Garcia v. State, 43 S.W.3d 527 (Tex. Crim. App. 2001) (reasonable-suspicion requirements)
- State v. Castleberry, 332 S.W.3d 460 (Tex. Crim. App. 2011) (reasonable suspicion can coexist with innocent explanations)
- Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (totality-of-circumstances test for investigatory detentions)