Samuel Lancaster, IV v. State
12-15-00166-CR
| Tex. App. | Nov 2, 2015Background
- Samuel Lancaster IV was indicted for evading arrest with a vehicle (enhanced/third-degree) and possession of marijuana (>4 oz but <5 lbs, state-jail felony). The two indictments were consolidated.
- Lancaster waived a jury; a bench trial was held May 15, 2015. The judge found him guilty on both counts.
- Evidence included dash‑cam and patrol videos/photos, testimony from multiple officers describing a high‑speed pursuit (100–120 mph), spike strips deployment, discovery of ~1 lb of marijuana and drug paraphernalia in a backpack, and Lancaster’s own testimony admitting the marijuana and describing fear as his motive for fleeing.
- The trial court found a deadly‑weapon finding (motor vehicle) on the evading count and sentenced Lancaster to 8 years TDCJ‑ID for evading and 2 years in state jail for possession, to run concurrently.
- Appellate counsel filed an Anders brief concluding the record contains legally sufficient evidence, no preserved error in exhibit admission or sentencing, and no record‑based Strickland ineffective‑assistance claim; counsel requested leave to withdraw.
Issues
| Issue | Plaintiff's Argument (Lancaster) | Defendant's Argument (State) | Held (Appellate counsel's conclusion) |
|---|---|---|---|
| Legal sufficiency of evidence for evading arrest and possession | Lancaster argued he was scared, unfamiliar with area, and did not intend to create danger; contested elements impliedly challenged | State relied on officer testimony, video/photos, discovery of marijuana and paraphernalia, and Lancaster’s own admissions | Appellate counsel: evidence was legally sufficient to support both convictions (no controverting evidence) |
| Admission of State’s Exhibits 1–25 / objections | Lancaster implicitly challenges possible evidentiary rulings | State offered videos, photos, physical evidence; no timely preservation of objections in record | Appellate counsel: no preserved error; exhibits admitted without objection; no reversible abuse of discretion |
| Sentence disproportionality (Eighth / Fourteenth Amendments) | Lancaster argued 8 years (evading) and 2 years (possession) are excessive given facts and his background | State: sentences fall within statutory ranges (3rd degree: 2–10 yrs; state jail: 6 mo–2 yrs) and no contemporaneous Eighth Amendment objection was made | Appellate counsel: sentence within statutory range and complaint was not preserved; no per se cruel and unusual punishment shown |
| Ineffective assistance of counsel at sentencing | Lancaster contended counsel failed to mitigate or present mitigation at sentencing | State observed record shows counsel cross‑examined and presented Lancaster’s testimony and waived PSI | Appellate counsel: on the record, no Strickland basis; presumption of effective assistance not rebutted |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (standards for appointed counsel filing a brief asserting appeal is frivolous)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong standard for ineffective assistance of counsel)
- Jackson v. Virginia, 443 U.S. 307 (1979) (legal‑sufficiency review—evidence viewed in light most favorable to verdict)
- Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007) (appellate review deference to factfinder on credibility and weight)
- Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1990) (abuse‑of‑discretion standard for evidentiary rulings)