Byron Keith Lawhon v. State, 10-16-00040-CR

On Jan 23, 2015 two pickup trucks towing camper trailers entered Texan RV Ranch and parked overnight; drivers were to pay the next day.
The next day an RV park manager recognized appellant Byron Lawhon (on the park’s blacklist) near one trailer; someone using the alias Wayne Davis had called to say he would pay.
Lawhon left the park in a gold Ford pickup towing one trailer; park personnel called police after he departed and he made no attempt to recover the trailers.
Police found the trailer locks punched out, no keys, and VIN checks showed both trailers had been stolen from a secured storage facility in Justin; owners denied permission to take them.
Evidence included: recent possession, punched locks, use of an alias, temporally close arrival and towing, no explanation for possession, and Lawhon’s prior theft convictions under similar circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Lawhon had intent to deprive owners of trailers (theft under Tex. Penal Code § 31.03(a))	State: cumulative circumstantial evidence (recent possession, punched locks, alias, towing one trailer, no explanation, prior similar convictions) permits reasonable inference of intent	Lawhon: mere brief possession is insufficient; possession alone does not prove intent to permanently deprive	Court affirmed: viewing evidence in light most favorable to prosecution, a rational juror could infer requisite intent and uphold convictions

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
Brooks v. State, 323 S.W.3d 893 (Texas standard for reviewing evidence)
Clayton v. State, 235 S.W.3d 772 (deference to jury inferences)
Torres v. State, 466 S.W.3d 329 (possession plus other facts required to infer theft)
Sutherlin v. State, 682 S.W.2d 546 (possession alone insufficient)
Rollerson v. State, 227 S.W.3d 718 (recent unexplained possession permits inference of theft)