Law School Case Brief
St. Clair v. State - 26 S.W.3d 89 (Tex. App. 2000)
The fifth element of the offense of "failure to stop and render aid" can be satisfied by proof that an operator of a vehicle knowingly involved in an accident involving injury or death: (1) failed to immediately stop his vehicle at the scene or as close to the scene as possible; (2) failed to immediately return to the scene if he did not stop there; or (3) failed to remain at the scene until he had: (a) given his name and address, the registration number of his vehicle, and the name of his liability insurer to any others involved in the collision; (b) shown his driver's license to anyone involved in the collision, if requested; or (c) provided any person injured in the accident reasonable assistance, including transporting or making arrangements for transporting the person to a physician or hospital for medical treatment if it was apparent that treatment was necessary, or if the injured person requested transportation. Tex. Transp. Code Ann. §§ 550.021(a), (c), 550.023.
Defendant James St. Clair collided with a car and drove a block away. When an officer radioed for medical assistance, St. Clair started the car, accelerated, and drove it at the officer. A Texas state court convicted him of aggravated assault on a public servant, failure to stop and render aid, and intoxication assault. The court sentenced St. Clair to 16 years' imprisonment for the aggravated assault and five years' imprisonment for each of the remaining offenses and decreed that his sentences run concurrently. St. Clair appealed arguing, among other things, that the evidence was legally insufficient to support the verdict on any of the three offenses.
Were St. Clair's convictions proper?
The appellate court affirmed. Although the indictment did not allege the manner in which St. Clair used his car to threaten the officer, the only common sense meaning of the indictment was that St. Clair drove it in an intentionally or knowingly assaultive manner, threatening imminent serious bodily injury or death. The indictment's deadly weapon allegation did not need to specify the manner and means of use of the weapon as required for pleading the primary offense in an indictment. Regarding insufficient evidence claims, when St. Clair turned his car in the officer's direction and began accelerating, he threatened imminent bodily injury by his conduct sufficient to convict. Finally, when St. Clair left the accident scene without giving his name and address to the victim, he committed the offense of failure to stop and render aid.
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