Rosa Spears v. State, 02-17-00218-CR

Around 11:00–11:30 p.m. on April 22, 2016, Rosa Spears drove her pickup off the road in Lewisville, struck and broke a utility pole, and airbags deployed. She then drove 472 feet, parked, and left the scene.
Officers found Spears’s credit card, driver’s license, and a police badge wallet near the accident; a K-9 and officers searched for her out of concern for injury.
An off-duty Lewisville officer (Laura Smith) picked Spears up about a half-mile from the crash; Spears declined hospital care, said she was tired, and asked to go to Smith’s house instead of retrieving her pickup.
Spears later called her watch commander and left a voicemail for the Lewisville hit-and-run investigator the next morning but never provided required insurance, VIN, or address information or otherwise completed the notification process.
The utility company quantified pole damage at $2,729.90. At trial, officers testified a driver must notify the property owner when property is damaged. The jury convicted Spears of duty on striking structure, fixture, or highway landscaping (Class B misdemeanor); the court suspended jail time and placed her on nine months’ community supervision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that defendant failed to take "reasonable steps" to locate/notify owner under Tex. Transp. Code §550.025	Spears: she took reasonable steps — left a voicemail and her insurer contacted the utility company by Monday to arrange payment.	State: Spears left the scene, did not personally notify owner, did not provide required info to investigator, and failed to follow up; jury could find steps were unreasonable.	Court: Evidence (and reasonable inferences) sufficient; jury reasonably found Spears did not take reasonable steps.

Jackson v. Virginia, 443 U.S. 307 (constitutional standard for sufficiency of the evidence)
Jenkins v. State, 493 S.W.3d 583 (Tex. Crim. App.) (applying Jackson sufficiency review)
Blea v. State, 483 S.W.3d 29 (Tex. Crim. App.) (deference to factfinder on credibility)
Montgomery v. State, 369 S.W.3d 188 (Tex. Crim. App.) (limitations on reweighing evidence on review)
Murray v. State, 457 S.W.3d 446 (Tex. Crim. App.) (presuming factfinder resolved conflicting inferences in favor of verdict)
Baird v. State, 212 S.W.3d 624 (Tex. App. — Amarillo) (jury may find delayed contact does not satisfy "reasonable steps")