Sammy Vidales v. State, 474 S.W.3d 274

Appellant Sammy Vidales was convicted by jury of evading arrest or detention with a vehicle, based on events on October 7, 2012, and sentenced to 62 years after two enhancements were found true.
Officer observed an SUV with headlights off in a parking lot; Driver, Vidales, was ordered to stop and initially complied but drove away.
Approximately five hours later, Vidales was stopped again by the same officer; Vidales exited the SUV and was handcuffed, but attempted to flee after the handcuffs failed, and crashingly fled in the SUV.
Detention at the apartment complex lacked reasonable suspicion; detention at the motel parking lot occurred during pursuit and was supported by reasonable suspicion or later arrest.
Trial involved multiple encounters: apartment complex, motel encounter, and the motel continuation; question presented whether these constituted a single offense or multiple events.
The trial court ultimately remanded for a punishment-only retrial due to errors in the sentencing scheme under section 12.42(d).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Vidales’ initial detention lawful?	Vidales argues no reasonable suspicion supported the initial detention.	State concedes lack of reasonable suspicion for the apartment encounter.	First issue overruled; later detention at the motel supported by reasonable suspicion; issue regarding initial detention largely waived.
Was trial counsel ineffective?	Counsel failed to request an explanatory instruction, file a motion to quash, compel election, and object where appropriate.	Record shows strategy and lack of developed record; some claims are unreviewable on direct appeal.	Second issue overruled; ineffective-assistance claim not established on the record presented.
Did the court err by omitting unanimity instructions on the prosecution event?	Jury could convict if some jurors believed apartment complex evading and others believed motel evading.	Unanimity not required on alternate methods; single offense alleged.	Third issue overruled; no reversible error because gravamen was evading detention on Oct. 7, 2012.
Is Vidales subject to an illegal sentence due to 12.42(d) requirements not being met?	Sentence exceeded the statutory maximum because sequential finality of prior felonies wasn’t found.	Indictment alleged three prior felonies; court failed to instruct sequential finality; egregious harm acknowledged.	Fourth issue sustained; sentence reversed and remanded for new punishment trial under article 44.29(b).

York v. State, 342 S.W.3d 528 (Tex. Crim. App. 2011) (lawfulness of detention reviewed for legal sufficiency; reasonable suspicion required)
Woods v. State, 153 S.W.3d 413 (Tex. Crim. App. 2005) (standard for evaluating sufficiency of evidence)
Rodriguez v. State, 578 S.W.2d 419 (Tex. Crim. App. 1979) (absence of reasonable suspicion invalidates detention)
Crain v. State, 315 S.W.3d 43 (Tex. Crim. App. 2010) (reasonable suspicion necessary for investigative detention; objective standard)
Delafuente v. State, 414 S.W.3d 173 (Tex. Crim. App. 2013) (reasonable inferences from facts; totality of circumstances)
Ford v. State, 158 S.W.3d 488 (Tex. 2005) (reasonable suspicion, objective basis for stop)
Miranda v. State, 391 S.W.3d 302 (Tex. Crim. App. 2012) (unanimity when alternative means exist; multiple modes of offense)
Young v. State, 341 S.W.3d 417 (Tex. Crim. App. 2011) (unanimity allowed for general verdict with alternative means)
Jordan v. State, 256 S.W.3d 286 (Tex. Crim. App. 2008) (sequential finality under 12.42(d) required for enhanced punishment)
Ex parte Parrott, 396 S.W.3d 531 (Tex. Crim. App. 2013) (illegality of sentence when enhancements improperly applied)
Farias v. State, 426 S.W.3d 198 (Tex. App.—Houston [1st Dist.] 2013) (citing sentencing range for overstep of statutory limits)