Desmond Juwon Woods v. State, 06-15-00063-CR

Appellant Desmond Juwon Woods was convicted by a jury of felony criminal mischief and sentenced to 8 years; this brief seeks reversal for insufficiency of evidence. The case was tried with a companion theft-of-copper case (two-year sentence) to run concurrently.
Victim Alice Bullock reported on Dec. 24, 2012 that copper wiring had been stripped from four of six chicken houses; repair estimates exceeded $23,000 (testimony estimating replacement wire as 12/2 Romex, 4,070 feet per house).
Deputy Hershel Stroman followed a trail of yellow styrofoam insulation from the chicken houses through woods to a burn pile behind 585 CR 1231 (Woods’s listed residence), where similar insulation pieces were found and a pickup with a license matching Woods’s scrap-sale receipts was observed.
Scrap-yard owner Mike Rice and records showed Woods sold multiple lots of #1 copper to Daingerfield Iron & Metal in Nov–Dec 2012, including sales near the burglary date; some material Rice received appeared burned and was not the same gauge as the chicken-house wire.
No witness testified to personally observing Woods stripping the chicken-house wiring or to recovering the specific stolen chicken-house wire from Woods; appellant argues the evidence shows at most presence and suspicion, not proof beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to sustain a criminal-mischief conviction	State relies on circumstantial evidence: insulation trail to Woods’s property and burn pile, matching truck/receipt records showing Woods sold copper near the relevant dates, and repair costs showing substantial pecuniary loss	Woods contends no direct evidence links him to the damage; presence of insulation or vehicle/receipts is speculative and insufficient to prove he intentionally or knowingly damaged property	Not decided in this brief — appellant asks the court to reverse and render an acquittal for insufficiency of the evidence (trial-court judgment challenged)

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for reviewing legal sufficiency under Jackson-Brooks framework)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence can suffice but inference must be reasonable and supported by facts)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (evidence must be sufficient for any rational trier of fact to find guilt beyond a reasonable doubt)
Beardsley v. State, 738 S.W.2d 681 (Tex. Crim. App. 1987) (cumulative force of evidence can establish guilt)
Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (circumstantial and direct evidence accorded the same sufficiency review)