Lonnie Ray Barfield, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals reversed the intermediate appellate court's judgment and affirmed the district court's conviction, holding that in a bench trial without a jury, evidence introduced at the punishment stage may be considered when reviewing the sufficiency of the evidence of guilt. The majority reasoned that the statutory bifurcation provision applies only to jury trials, so the trial was improperly bifurcated but that error does not preclude consideration of later evidence. A dissent argued that the court lacked jurisdiction to reach the merits and would have upheld the conviction as a misdemeanor DWI.