Patrick Henderson Cooper v. State, 01-16-00982-CR

On December 4, 2014, Patrick Henderson Cooper and co-defendants agreed to and executed an armed robbery at a warehouse to steal cocaine; undercover officers were the victims.
Cooper was armed during the robbery and arrested the same day.
Two indictments: possession with intent to deliver a controlled substance (cause no. 1450541) and engaging in organized criminal activity with underlying aggravated robbery (cause no. 1489378).
Cooper pleaded guilty to both charges and admitted enhancement paragraphs (use of a deadly weapon and a prior felony).
The trial court sentenced Cooper to 30 years’ confinement on each count, to run concurrently; timely appeals followed.
Cooper challenged the possession conviction on double jeopardy grounds, arguing multiple punishments for the same act.

Issue	Cooper's Argument	State's Argument	Held
Whether punishing Cooper for both possession with intent to deliver and engaging in organized criminal activity violates double jeopardy	Cooper argued he was punished twice for the same act—possession of the cocaine	The State argued the organized-crime conviction was based on armed robbery as the underlying offense, not possession; the two offenses require different elements	Court held no double jeopardy violation; offenses have distinct elements under Blockburger and cumulative punishment authorized where legislature permits

Brown v. Ohio, 432 U.S. 161 (prohibits multiple punishments/prosecutions for the same offense under Double Jeopardy)
Blockburger v. United States, 284 U.S. 299 (same-elements test for double jeopardy)
Missouri v. Hunter, 459 U.S. 359 (legislative intent can authorize cumulative punishment)
Ex parte Chaddock, 369 S.W.3d 880 (Texas precedent on double jeopardy protections)
Villanueva v. State, 227 S.W.3d 744 (Blockburger application does not override clear legislative intent)