Court of Criminal Appeals of Texas
Hubert Richard Spradling, Appellant v. the State of Texas, Appellee
June 21, 19891989 Tex. Crim. App. LEXIS 137
Summary
The Court of Criminal Appeals of Texas affirmed Spradling's convictions for failure to stop and render aid, holding that each victim constitutes a separate statutory offense and that the legislature may permit multiple prosecutions. It rejected the appellant's double‑jeopardy arguments, finding the Blockburger test inapplicable and emphasizing legislative intent. Two dissenting judges argued that the successive prosecutions violate the Fifth Amendment and Texas constitutional double‑jeopardy protections.