Ernesto Carlos Trevino v. State, 608 S.W.3d 344

Trevino advertised a deer-hunting-for-vehicle barter; Stern traded a jet ski and cash for hunting privileges and left the jet ski and certificate of title with Trevino but did not sign the back of the title transferring ownership.
Several months later Trevino posted the jet ski for trade; he traded it to Nguyen for a truck and, at the trade, signed the back of the jet-ski title using the name "Kurt Stern."
Stern testified he never authorized that signature; Nguyen took the title to register the jet ski and later received registration documents in his name.
A Texas Parks & Wildlife game warden investigated, flagged the title, and advised Nguyen not to operate the jet ski.
A jury convicted Trevino of third-degree felony forgery (governmental record); the trial court assessed deferred 4‑year confinement (suspended), 4 years’ community supervision, $1,500 fine, and $4,000 restitution.
The court of appeals reversed and rendered an acquittal, holding the State failed to prove Trevino acted with intent to defraud or harm another.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Trevino)	Held
Sufficiency: intent to defraud or harm required for forgery conviction	Trevino knowingly forged Stern’s signature to defraud Nguyen (and harmed him by preventing registration) and lied to Stern about the signature	Trevino believed he owned the jet ski (transaction with Stern was effectively complete), signed only because the paperwork was incomplete—no intent to defraud or harm	Reversed — evidence insufficient to prove intent to defraud or harm; acquittal rendered
Theory of prosecution differed from indictment	State relied on conduct not charged	Trevino argued conviction rested on unindicted theory	Not reached (acquittal on sufficiency of element)
Admission of extraneous-offense evidence; limiting instruction	State offered extraneous-offense evidence	Trevino argued admission was improper and requested limiting instruction	Not reached (acquittal on sufficiency of element)

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-the-evidence standard)
Hooper v. State, 214 S.W.3d 9 (Texas Crim. App. 2007) (circumstantial evidence can support conviction)
Leroy v. State, 512 S.W.3d 540 (discusses totality-of-circumstances for intent in forgery cases)
Okonkwo v. State, 398 S.W.3d 689 (intent to defraud must be proved from facts)
Parks v. State, 746 S.W.2d 738 (mere possession or presentment of forged instrument insufficient to prove intent)
Oldham v. State, 5 S.W.3d 840 (knowledge that an instrument is forged allows inference of intent)
Huntley v. State, 4 S.W.3d 813 (knowledge of forgery supports inference of intent)
Bohannan v. State, 546 S.W.3d 166 (deference to jury on credibility and weight of evidence)