Timothy Paul Bates v. State
06-14-00105-CR
Tex. App.Apr 6, 2015Background
- Appellant Timothy Bates was tried in Hunt County Court at Law No. 2 and convicted by a jury of Driving While Intoxicated; sentence: 180 days jail probated for 12 months, $400 fine, costs, and 50 hours community service.
- Incident occurred Sept. 1, 2013 at ~1:00 a.m.; Kwik-Check clerk Phillip Erickson called non‑emergency police to report Bates appeared intoxicated and had frightened him.
- Officer Brandon West stopped Bates, who brought a Snickers bar out of the vehicle and required repeated instructions for sobriety testing.
- Officer West observed 6 out of 6 clues on the Horizontal Gaze Nystagmus (HGN) test; Bates admitted taking prescription medication earlier that evening.
- Jury viewed dashcam video and heard testimony from the clerk and the officer; conviction rested on totality of circumstances and field sobriety results.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal sufficiency of evidence to support DWI conviction | State: Evidence (lay witness fear, officer observations, HGN 6/6, defendant statements, video) is sufficient for a rational juror to find intoxication beyond a reasonable doubt | Bates (as preserved in appellant materials): contends evidence insufficient (implicit) to prove intoxication beyond reasonable doubt | Court should affirm: viewing evidence in light most favorable to verdict, a rational juror could find elements proven beyond reasonable doubt |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (legal‑sufficiency standard: evidence must permit any rational trier of fact to find guilt beyond a reasonable doubt)
- Dewberry v. State, 4 S.W.3d 735 (Tex. Crim. App. 1999) (appellate court must not reweigh evidence or assess witness credibility on sufficiency review)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (legal sufficiency review considers combined and cumulative force of all evidence)
