## Facts

- Deputy James McClanahan found Chad William Murray’s truck parked partly on the shoulder and partly in a driveway off Highway 22 in the early morning hours.
- The truck’s headlights were on; exhaust vapors suggested the engine was running.
- The deputy approached and found Murray reclined in the driver’s seat, asleep.
- The deputy confirmed the engine was running, the transmission was in “park,” and the radio was on loudly.
- The deputy had to knock on the window for several minutes to wake Murray.
- Murray was alone; the deputy observed no other person in or near the vehicle.
- After Murray awoke, the deputy detected signs of intoxication, Murray admitted drinking, and he failed field sobriety tests.
- Murray was arrested and later convicted by a jury of misdemeanor DWI in a public place.
- The court of appeals reversed for legally insufficient evidence of “operating” and rendered an acquittal.

## Issues

1. Whether legally sufficient evidence supported the “operating a motor vehicle” element of Texas DWI when the defendant was found asleep behind the wheel of a running vehicle with the transmission in “park,” and no officer observed the vehicle in motion.

## Decision

- The Texas Court of Criminal Appeals reversed the court of appeals’ judgment.
- The court held that, viewing the evidence in the light most favorable to the verdict, a rational jury could find beyond a reasonable doubt that Murray was “operating” the vehicle.
- The jury’s guilty verdict was reinstated, and the DWI conviction stood.

## Legal Principles

- In reviewing legal sufficiency, courts ask whether any rational factfinder could have found the essential elements beyond a reasonable doubt when evidence is viewed in the light most favorable to the verdict.
- When the record supports conflicting inferences, appellate courts presume the factfinder resolved conflicts in favor of the verdict and defer to that resolution.
- For Texas DWI, “operating” is not limited to observing the vehicle in motion; it may be proved by circumstantial evidence and may include actions that affect the functioning or use of the vehicle.
- A defendant’s presence alone in the driver’s seat of a running vehicle, coupled with surrounding circumstances (time, location, vehicle status), can support an inference of operation.

## Conclusion

The court held that circumstantial evidence—especially a running engine and the defendant alone in the driver’s seat—permitted a rational jury to find “operation” for Texas DWI purposes, and it rejected an appellate reweighing of competing inferences on sufficiency review.


Murray v. State, 457 S.W.3d 446 (Tex. Crim. App. 2015)