Gengnagel v. State and Lacour v. State

In Gengnagel v. State and Lacour v. State, 980 S.W.2d 525 (Tex. App.-Beaumont 1998), rev'd, 8 S.W.3d 670 (Tex. Crim. App. 2000), the information alleged the defendant exposed his genitals and then repeated "exposition of his genitals" as the act constituting recklessness. Gengnagel, 748 S.W.2d at 228. The court of criminal appeals determined that the information did not allege "any act or circumstances" to show this exposition was done in a reckless manner. Gengnagel, 748 S.W.2d at 230. The court noted that the State's evidence showed the defendant exposed himself after seeing a specific individual approach him in a public park. Gengnagel, 748 S.W.2d at 230 n.2.