Cook v. State (1992)
In Cook v. State, 840 S.W.2d 384 (Tex. Crim. App. 1992), the defendant stole a hubcap from a woman's car and during his flight after the theft assaulted two police officers. Cook, 840 S.W.2d at 385-86.
The court held that because there was only one theft from one individual, there could be only one conviction for aggravated robbery, regardless of the number of victims of assaultive conduct. Cook, 840 S.W.2d at 389.