Court of Criminal Appeals of Texas
Ex Parte Mark Anthony Hawkins, Applicant
December 8, 19991999 Tex. Crim. App. LEXIS 137
Summary
The Court held that the applicant's two aggravated robbery convictions did not violate the Double Jeopardy Clause because robbery's allowable unit of prosecution is each victim, and the applicant assaulted two victims; the Court overruled its prior decisions in Crosby, Simmons, and Cook. Two concurring opinions argued the majority either overreached or that the guilty pleas waived any double‑jeopardy claim.