Aaron Liverman v. State, 448 S.W.3d 155

Liverman was convicted by bench of securing execution of a document by deception involving a $20,000 to $100,000 pecuniary interest.
Indictment alleged Liverman caused Cynthia Mitchell to sign or execute a miscellaneous general fee affidavit.
Mitchell, Denton County Clerk, testified about filing/recording such affidavits and the clerks' role in finalizing the document.
Liverman pleaded true to an enhancement; trial court imposed a two-year term and $500 fine, suspended to community supervision for two years.
The State argued the county clerk’s signing/recording of the affidavit or the cover sheet satisfied the element; Liverman contested this interpretation.
The court ultimately held the evidence did not prove Liverman caused the clerk to sign or execute the affidavit, necessitating acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for signing/executing element	Liverman (State) claims clerk signed/executed the affidavit.	Liverman contends clerk signing/exec not shown; filing/recording not the same as signing/executing.	Evidence insufficient; acquittal.
Due process challenge on sufficiency	Liverman asserts due process violation from insufficient proof.	Liverman argues no reliable proof of the required element.	Not reached; first issue dispositive.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of evidence)
Tibbs v. Florida, 457 U.S. 31 (U.S. 1982) (reversal/bar to acquittal when evidence is insufficient)
Winfrey v. State, 393 S.W.3d 763 (Tex. Crim. App. 2013) (Tex. sufficiency review framework)
Byrd v. State, 336 S.W.3d 242 (Tex. Crim. App. 2011) (variance of proof doctrine in indictments)
DeWitt v. Harris Cnty., 904 S.W.2d 650 (Tex. 1995) (distinction between signing/executing vs. filing/recording)
Uribe v. State, 7 S.W.3d 294 (Tex. App.—Austin 1999) (statutory construction and meanings of terms)
Boykin v. State, 818 S.W.2d 782 (Tex. Crim. App. 1991) (statutory-purpose interpretation)