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.