Nguyen v. State

In Nguyen v. State, 1 S.W.3d 694 (Tex.Crim.App. 1999, the Court had to decide whether the evidence adduced at trial proved the existence of a combination. There, the evidence showed that the defendant was guilty of murder, but there was no evidence of a continuing course of criminal activity. The evidence showed that a confrontation erupted between the defendant and his friends on the one hand and the victim and his friends on the other, that the defendant and his friends left the scene, and that they later returned with the murder weapon. There was no evidence that any of the actors intended to commit more than one crime. The Court recognized that that fact pattern did not fit within the language or spirit of the organized crime statute.