Shaun Adrian Jackson v. State
530 S.W.3d 738
| Tex. App. | 2017Background
- At ~8:00 a.m., Deputy Constable David Vest pursued a small blue Mazda that sped through a school zone; Vest activated lights/siren and dashcam recorded pursuit.
- Vest saw a male driver and female passenger; during a traffic block on I-10 the Mazda rammed the patrol car; Vest made eye contact with the driver and later identified appellant Shaun Jackson at trial.
- Shortly after the pursuit ended, the damaged Mazda drove onto John Graham’s business property; Graham saw a man exit the driver’s side, walk to the trunk within inches of him, and later identified appellant at the scene.
- Officers found appellant and a woman hiding under a house within a short distance and returned them to Graham’s facility where Graham identified them.
- Vest later identified appellant at the constable’s station (~8.5 hours after the pursuit). Appellant was convicted by a jury for evading arrest with a motor vehicle.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Jackson) | Held |
|---|---|---|---|
| Whether evidence is legally sufficient to prove Jackson was the Mazda’s driver | Vest’s in-court ID, Graham’s eyewitness ID, circumstantial facts (damage, flight, hiding) suffice to prove driver identity beyond a reasonable doubt | Identification unreliable: Vest had limited opportunity/attention during pursuit, inconsistent dispatch description, delay between event and ID; Biggers factors show unreliability | Court: Evidence is legally sufficient; jury could credit IDs and circumstantial evidence and resolve inconsistencies in favor of verdict |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for legal-sufficiency review)
- Neil v. Biggers, 409 U.S. 188 (factors for assessing reliability of pretrial identifications)
- Hooper v. State, 214 S.W.3d 9 (circumstantial evidence can support conviction)
- Temple v. State, 390 S.W.3d 341 (application of Jackson standard in Texas)
- Mosley v. State, 983 S.W.2d 249 (jury as sole judge of eyewitness credibility)
