Craig Sanders v. State

CourtCourt of Appeals of Texas
DecidedAugust 30, 2018
Docket01-17-00113-CR
StatusPublished

This text of Craig Sanders v. State (Craig Sanders v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craig Sanders v. State, (Tex. Ct. App. 2018).

Opinion

Opinion issued August 30, 2018

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-17-00113-CR ——————————— CRAIG SANDERS, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 405th District Court Galveston County, Texas Trial Court Case No. 16CR1430

MEMORANDUM OPINION

A jury found appellant, Craig Sanders, guilty of the felony offense of evading

arrest, or detention, in a motor vehicle.1 After he pleaded true to the allegations in

1 See TEX. PENAL CODE ANN. § 38.04 (Vernon 2016). two enhancement paragraphs that he had twice been previously convicted of felony

offenses, the jury assessed his punishment at confinement for forty-five years. In

two issues, appellant contends that the evidence is insufficient to support his

conviction and the trial court erred in admitting certain evidence.

We affirm.

Background

Texas City Police Department (“TCPD”) Officer C. Ham testified that on May

26, 2016, while on patrol around midnight, he performed a “keep check” of the

parking lot of the Economy Lodge hotel in Galveston County, Texas to “check[] for

any illegal activity or . . . anything that need[ed] to be addressed.” (Internal

quotations omitted.) As he drove his patrol car through the parking lot, Ham saw a

parked car, a silver Chrysler Sebring (the “silver car”), with “back-end damage” and

an expired registration. Ham subsequently left the Economy Lodge hotel’s parking

lot, drove “half a block,” and parked his patrol car in the parking lot of a hair salon.

As Officer Ham sat in his parked patrol car, he saw the silver car exit the

parking lot of the Economy Lodge hotel and drive down the road. Because Ham

knew that the car had an expired registration, he followed it in his patrol car so that

he could make a traffic stop. As Ham drove a short distance behind the silver car

with his patrol car’s emergency lights activated, the silver car continued on. After

the silver car made a sudden turn, Ham “bumped [his patrol car’s] siren . . . a couple

2 of times” to get the driver’s attention. The silver car then accelerated quickly and

“took off.”

After the silver car had driven a little farther, Officer Ham saw the driver’s

side door of the car open and the driver jump out and start running. The driver of

the silver car was “a black male[,] wearing a black shirt with some white lettering

on it” and black shorts, with white trim. Ham stopped his patrol car and attempted

to follow the driver; however, he stopped his pursuit when he heard the silver car hit

a curb and start rolling backwards “through the roadway and toward[] some parked

cars.” Other law enforcement officers subsequently arrived at the scene, but they

did not locate the driver.

Officer Ham returned to the Economy Lodge hotel at around 1:43 a.m. to view

its surveillance videotape recording from that night. After speaking with the hotel

clerk, Rhitejak Nikhil Ingreji, Ham viewed the videotape recording. He saw “a

subject come out of . . . [r]oom 236” and “walk directly towards the camera,”

wearing the same clothing2 that Ham had seen the driver of the silver car wearing

when he “jumped out of the car and ran.” The person in the videotape recording

then walked downstairs, got into the silver car, and drove around the hotel’s parking

lot to leave.

2 Officer Ham described the person in the videotape recording as “a black male, wearing a black [t]-shirt with white logos on the front, with black shorts with white trim.”

3 After viewing the surveillance videotape recording, Officer Ham proceeded

to room 236. A woman answered the door, and Ham received consent to enter the

room. He then saw a pair of shorts and “a black [t]-shirt laying on the foot of the

bed,” which matched the ones worn by the driver of the silver car. Ham noted that

the black shirt was “fairly wet . . . maybe from sweating.” When appellant exited

the bathroom in the room, he appeared “a little winded,” was sweating, and was not

wearing a shirt.

Officer Ham further testified that he first saw the black shirt that he found in

room 236 when the driver of the silver car “jumped out of the [car] and took off

running.” He next saw the black shirt while viewing the surveillance videotape

recording from the Economy Lodge hotel. He then saw the same black shirt on the

floor of room 236, after the woman answered the hotel room door. The trial court

admitted into evidence the actual black shirt and shorts collected by Ham from the

Economy Lodge hotel room. Ham noted that the silver car was registered to a person

named Fabio Mejia.

During Officer Ham’s testimony, the trial court admitted into evidence State’s

Exhibit 3, the videotape recording from Ham’s patrol car. In that videotape

recording, a black male, wearing a black shirt, with a white logo, and dark shorts,

with white trim, can be seen exiting a silver car and running away. The trial court

also admitted into evidence State’s Exhibits 1A and 1B, the surveillance videotape

4 recording from the Economy Lodge hotel. In that videotape recording, a black male,

wearing a black shirt, with a white logo, and dark shorts, with white trim, can be

seen exiting a hotel room, getting into a silver car parked in the hotel’s parking lot,

and driving away. While watching the surveillance videotape recording during trial,

Ham noted that at 12:30 a.m. on May 26, 2016, the driver of the silver car can be

seen getting into the car. At 12:32 a.m., the silver car is shown exiting the Economy

Lodge hotel’s parking lot. And at 12:33 a.m., Ham attempted to stop the silver car.

Sufficiency of Evidence

In his first issue, appellant argues that the evidence is insufficient to support

his conviction because it “conclusively establishes a reasonable doubt concerning

his identity as the driver of the [silver car]” and “there is only a modicum of evidence

linking the driver of the [silver car] to motel room 236.”

We review the legal sufficiency of the evidence by considering all of the

evidence in the light most favorable to the jury’s verdict to determine whether any

“rational trier of fact could have found the essential elements of the crime beyond a

reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 318–19, 99 S. Ct. 2781, 2788–

89 (1979); Williams v. State, 235 S.W.3d 742, 750 (Tex. Crim. App. 2007). Our role

is that of a due process safeguard, ensuring only the rationality of the trier of fact’s

finding of the essential elements of the offense beyond a reasonable doubt. See

Moreno v. State, 755 S.W.2d 866, 867 (Tex. Crim. App. 1988). We give deference

5 to the responsibility of the fact finder to fairly resolve conflicts in testimony, weigh

evidence, and draw reasonable inferences from the facts. Williams, 235 S.W.3d at

750. However, our duty requires us to “ensure that the evidence presented actually

supports a conclusion that the defendant committed” the criminal offense of which

he is accused. Id.

We note that in reviewing the sufficiency of the evidence, a court must

consider both direct and circumstantial evidence, as well as any reasonable

inferences that may be drawn from the evidence. See Clayton v.

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