Todd Dawayne Sturgis v. State, 12-19-00313-CR

Appellant Todd D. Sturgis was indicted for evading arrest in a vehicle (third-degree felony) with enhancements alleging a prior felony and that a motor vehicle was used or exhibited as a deadly weapon; he pled guilty to evading and true to the prior-conviction enhancement but denied the deadly-weapon allegation.
Officers Jeremy Charvoz and Zack Klein initiated a traffic stop after discovering outstanding warrants; Sturgis pulled into a convenience-store parking lot where other vehicles and patrons were present.
When officers approached and attempted to arrest him, Charvoz opened Sturgis’s driver-side door; while Charvoz’s hand was in the door and he leaned into the vehicle, Sturgis shifted into reverse, tires screeched, and Charvoz moved to avoid being struck.
Sturgis then drove erratically through the parking lot between a parked vehicle and the building, ran a red light, cut through ditches, and led officers on a pursuit with other motorists present; he eventually hit a tree, went through a barbed-wire fence, exited the vehicle, and fled.
At the punishment hearing the court admitted bodycam and in-car video and found the deadly-weapon allegation true; Sturgis was sentenced to 12 years and appealed, arguing the evidence was legally insufficient to support the deadly-weapon finding.

Issue	State's Argument	Sturgis's Argument	Held
Whether the evidence is sufficient to find Sturgis used/exhibited a motor vehicle as a deadly weapon during evading arrest	Video and officer testimony show Sturgis reversed with an officer partially in the door, drove recklessly through a populated parking lot and public roads with traffic, creating actual danger — supports deadly-weapon finding	Sturgis argues the door closed and the vehicle backed away without placing officers or the public in the path; driving was erratic but did not create actual danger, citing cases where courts found insufficient evidence	Affirmed. The court held a rational factfinder could find the vehicle was used in a manner capable of causing death or serious bodily injury (officer endangered by the reverse and public endangered during the pursuit)

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (endorses Jackson sufficiency standard for appellate review)
Jackson v. Virginia, 443 U.S. 307 (1979) (constitutional standard for sufficiency of the evidence)
Drichas v. State, 175 S.W.3d 795 (Tex. Crim. App. 2005) (motor vehicle not per se deadly weapon but may be when manner of use is capable of causing death or serious bodily injury; fact-specific inquiry)
Mann v. State, 58 S.W.3d 132 (Tex. Crim. App. 2001) (upholds deadly-weapon finding where defendant’s driving narrowly avoided a head-on collision)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence can be as probative as direct evidence)
Couthren v. State, 571 S.W.3d 786 (Tex. Crim. App. 2019) (distinguished — insufficient deadly-weapon finding where facts did not show dangerous manner of driving)