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Detta Sanders v. State
Citation: Not availableDocket: 07-07-00268-CR
Court: Court of Appeals of Texas; August 5, 2008; Texas; State Appellate Court
Original Court Document: View Document
Detta Sanders was indicted on six counts of theft, enhanced by three prior theft convictions. She entered a no contest plea without a punishment agreement and was sentenced to two years in a state jail. Sanders argued that the evidence was insufficient to elevate her misdemeanor thefts to felony status, claiming the State did not prove her prior convictions. The court disagreed, affirming the conviction based on several key points: 1. The appellate standard for legal sufficiency differs when a defendant pleads nolo contendere or guilty; the Jackson v. Virginia standard does not apply. 2. Prior theft convictions are jurisdictional elements necessary to elevate misdemeanor thefts to felonies, thereby granting the district court jurisdiction. 3. Each charge in the indictment was validly classified as a state jail felony under Texas law, given Sanders' prior convictions. 4. A judicial confession, which Sanders made by stipulating to the truth of the indictment allegations, suffices to support her conviction. 5. During the plea hearing, Sanders explicitly acknowledged her prior convictions, providing adequate proof despite the State's failure to introduce prior judgment copies. The court concluded that the evidence was legally sufficient to uphold the conviction, leading to the affirmation of the trial court's judgment.