David Leroy v. State, 512 S.W.3d 540

Leroy entered First Community Credit Union and presented a check payable to himself for $825 (purportedly for “roofing contractor work”), his state ID, and a BBVA debit card without prompting.
The teller observed the check was shaky-signed, had security features missing/altered, smelled of bleach, and appeared to have been washed; the teller and fraud investigator later confirmed suspicious alterations.
The account holder, Judy Smith, testified she had not written a check to Leroy, did not know him, and that two checks she had placed in her mailbox that morning included the check number used by the presented instrument.
Leroy left his check, ID, and card with staff while they investigated; he waited 45–60 minutes, became irate, left the credit union without his items, ran across the street, and was arrested.
The jury convicted Leroy of forgery; at sentencing enhancements were found true and he received five years’ imprisonment. Leroy appealed solely arguing legal insufficiency of evidence as to intent to defraud or harm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally sufficient to show Leroy acted with intent to defraud or harm (i.e., knew the check was forged)	The State: totality of circumstances (altered/washed check, short time from theft to presentment, Leroy presented ID/card unprompted, no relationship with maker, fled when confronted) permits inference he knew the check was forged	Leroy: mere presentment as payee, no false identification or verbal misrepresentation, no handwriting link, compliance with procedures—insufficient to prove knowledge/intent	Affirmed: a rational jury could infer beyond a reasonable doubt that Leroy knew the check was forged based on the totality of circumstances

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for legal-sufficiency review)
Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (use of hypothetically correct jury charge to measure elements)
Ramsey v. State, 473 S.W.3d 805 (Tex. Crim. App. 2015) (intent to defraud requires inference that defendant knew instrument was forged)
Johnson v. State, 425 S.W.3d 516 (Tex. App.—Houston [1st Dist.] 2012) (analysis of circumstantial evidence and short time frame between theft and presentment)
Pfleging v. State, 572 S.W.2d 517 (Tex. Crim. App. 1978) (possession/presentation alone insufficient to infer knowledge)
Stuebgen v. State, 547 S.W.2d 29 (Tex. Crim. App. 1977) (similar rule that absence of misrepresentation and payee status may undercut inference of knowledge)