Aaron Lee Rice, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that reckless driving is not a lesser‑included offense of aggravated assault with a deadly weapon when the indictment does not allege that the defendant drove a vehicle. Accordingly, the Court reversed the Dallas Court of Appeals' decision and remanded for further proceedings. The decision rests on the cognate‑pleadings approach requiring that all elements of the lesser offense be deducible from the charging instrument.