Court of Criminal Appeals of Texas
Vincent Henry Flowers, Appellant v. the State of Texas
April 18, 20072007 Tex. Crim. App. LEXIS 428
Summary
The Court of Criminal Appeals affirmed the court of appeals' judgment upholding the trial judge's finding that appellant had a prior 1995 Dallas County DWI conviction for enhancement purposes. Rejecting the premise that a certified written judgment (or its article 42.01 functional equivalent) is required, the Court held that Texas law prescribes no specific document or mode of proof: the State need only prove beyond a reasonable doubt that a prior conviction exists and that the defendant is linked to it, and a clerk-certified computer printout combined with the defendant's driver's license record satisfied that burden. Justice Johnson, concurring in the judgment (joined by Justice Price), urged caution with non-traditional records, insisting on ample identifying information and genuine corroboration rather than one agency speaking through two mouths.