Ronnie Barnett Bright v. State
05-15-01467-CR
| Tex. App. | Sep 29, 2016Background
- Ronnie Barnett Bright pleaded guilty (waived jury) to two offenses: evading arrest/detention with a motor vehicle and aggravated assault with a firearm.
- Trial court found him guilty in both causes and assessed five years’ imprisonment for each.
- Bright challenged (1) the evading sentence as unsupported by evidence and (2) the trial court’s jurisdiction to decide the aggravated assault case.
- The State argued Bright failed to preserve the sentencing complaint and that the district court had proper jurisdiction.
- The appellate court reviewed the record, found preservation and statutory-range principles dispositive on sentencing, and relied on prior precedent and local administrative rules for jurisdiction.
- Appellate court also corrected the judgments to reflect that pleas were "open" (no plea bargain), then affirmed as modified.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether five-year sentence for evading arrest was unsupported by evidence | Bright: court abused discretion; no evidence to justify five years | State: Bright failed to preserve error; sentence is within statutory range | Overruled; error not preserved and five years is within the 2–10 year statutory range |
| Whether trial court lacked jurisdiction to hear aggravated assault because case was not transferred to its docket | Bright: court had no jurisdiction absent transfer/order | State: court properly exercised jurisdiction under county rules/administrative practice and constitution | Overruled; court had jurisdiction per precedent and local administrative rules |
Key Cases Cited
- Rhoades v. State, 934 S.W.2d 113 (Tex. Crim. App. 1996) (constitutional rights may be waived)
- Castaneda v. State, 135 S.W.3d 719 (Tex. App.—Dallas 2003) (preservation requirement for appellate review of sentencing complaint)
- Kirk v. State, 949 S.W.2d 769 (Tex. App.—Dallas 1997) (punishment within statutory range is not excessive)
- Jackson v. State, 680 S.W.2d 809 (Tex. Crim. App. 1984) (sentence within statutory range will not be disturbed on appeal)
- Bourque v. State, 156 S.W.3d 675 (Tex. App.—Dallas 2005) (district court jurisdiction upheld under local administrative rules)
- Bigley v. State, 865 S.W.2d 26 (Tex. Crim. App. 1993) (appellate modification of clerical errors in judgments)
- Asberry v. State, 813 S.W.2d 526 (Tex. App.—Dallas 1991) (modifying judgments to reflect actual plea bargain status)