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Isaac Sanders v. State
Citation: Not availableDocket: 02-11-00091-CR
Court: Court of Appeals of Texas; July 5, 2012; Texas; State Appellate Court
Original Court Document: View Document
Isaac Sanders appeals his conviction for evading arrest and detention using a vehicle, arguing insufficient evidence to negate a necessity defense. The incident occurred on December 16, 2009, when Officer Donald Miller pursued Sanders after he allegedly ran two stop signs. During the pursuit, which reached speeds of nearly 100 mph and included driving with headlights off, Sanders fled because he was intoxicated and lacked a driver’s license. After his arrest, Sanders initially claimed he fled to avoid impounding the vehicle, but later suggested he intended to return it home. The State charged him, and during the trial, Sanders admitted to driving without a license and fleeing from the police but did not request a jury instruction on the necessity defense, which was also not included in the jury charge. The jury convicted Sanders, and he was sentenced to twelve months in state jail. The court affirmed the conviction, concluding that there was no legal justification for Sanders's actions. Sanders argues that his evasion of police was justified under the necessity defense, claiming the evidence for his conviction is insufficient to negate this defense. He contends that, once he presented evidence supporting his defense, the State must prove its case beyond a reasonable doubt rather than merely disproving his defense. The court reviews the evidence favorably for the prosecution to determine if any rational factfinder could conclude that Sanders intentionally evaded arrest while knowing the pursuing officer was a peace officer. The court outlines the elements of the offense of evading arrest: the individual must intentionally flee from a known peace officer who is lawfully attempting to detain them. In this case, testimony indicated that Sanders ran stop signs while being pursued by police, clearly demonstrating intentional flight. Sanders claims he fled to avoid having his girlfriend's car impounded, asserting this constituted a necessity. The necessity defense requires that the actor believes their actions are necessary to avoid imminent harm, the urgency of avoiding that harm outweighs the harm of violating the law, and there is no legislative intent to exclude the justification. However, Sanders also admitted to fleeing due to being unlicensed and intoxicated. The jury, even considering the necessity defense, could reasonably conclude that his reasons did not justify his actions. As such, the court affirms the trial court's judgment, overruling Sanders's appeal.