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Jacobs v. State5/20/2004
other occupants were found at the scene. Trooper Jay Alexander testified that the steering wheel had been damaged. Jacobs was diagnosed with bilateral lung contusion, bruising of the lungs, or atelectasis, collapse of the alveoli in the lungs. The medical records indicate that pneumonia could have been a possible cause of Jacob's injuries, but the injuries were also consistent with injury caused by a person's chest striking a steering wheel during an accident. Cobb testified that medical tests indicated Jacobs had a blood alcohol concentration in excess of three times the legal limit. As a result of the incident, Jacobs was charged, in addition to the DWI, with operation of a motor vehicle in violation of the financial responsibility law. Before the trial for DWI, Jacobs pled guilty to operation of a motor vehicle in violation of the motor vehicle liability insurance requirement. See Tex. Transp. Code §§ 601.051, 601.191 (Vernon 1999). One of the elements of this offense is that one must operate a vehicle without one of the enumerated financial responsibility measures including motor vehicle insurance. Id. A copy of Jacobs' plea concerning the lack of insurance was introduced into evidence. A guilty plea is an admission of all elements of a formal criminal charge. Ex parte Williams, 703 S.W.2d 674, 678 (Tex. Crim. App. 1986). Thus, Jacobs had previously admitted his guilt to an offense which required him to be the driver on the occasion in question.
Jacobs argues that there are numerous scenarios which would explain why only the driver's side door was open and that Jacobs was the only person found at the scene. Jacobs contends the driver could have pulled Jacobs out of the vehicle from the driver's side or that Jacobs could have exited the passenger side and closed the door. The driver could have fled the scene before the emergency medical personnel arrived. However, the State is no longer obligated to exclude every reasonable hypothesis other than guilt in circumstantial evidence cases. See Purvis v. State, 4 S.W.3d 118, 120 (Tex. App.—Waco 1999, no pet.); see also Geesa v. State, 820 S.W.2d 154, 160-61 (Tex. Crim. App. 1991), overruled in part on other grounds, Paulson v. State, 28 S.W.3d 570 (Tex. Crim. App. 2000).
The evidence contains circumstantial evidence that Jacobs was the driver. Furthermore, by entering a plea of guilty to driving without insurance, he admitted operating the vehicle at the time of this accident. When viewed in a light most favorable to the verdict, a rational person could have found Jacobs guilty beyond a reasonable doubt. The evidence supporting the verdict, considered alone, is strong enough that a rational juror could have found Jacobs guilty beyond a reasonable doubt. After weighing the evidence supporting and contravening the conviction, we conclude that the contrary evidence is not strong enough that the State could not have proven guilt beyond a reasonable doubt. Viewed in a neutral light, a rational juror could have found Jacobs guilty beyond a reasonable doubt. Therefore, the evidence was both factually and legally sufficient.
For the reasons stated, we affirm the judgment of the trial court.
Jack Carter Justice
Date Submitted: April 9, 2004
Do Not Publish
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