Ford, Joseph Clyde, PD-1677-15

Ford was convicted of failure to register as a sex offender, enhanced to a higher degree.
The indictment alleged an attempt to change address not later than seven days before the intended change.
Evidence showed Ford's registered address was a homeless shelter, with later assertion of living at a non-address “tent city.”
The State did not present evidence of a fixed new physical address; “tent city” was not shown to be an actual address.
The court followed Thomas v. State to require proof of an intended address change at least seven days prior, but found the evidence insufficient to prove a specific new address.
The Court of Appeals affirmed; Ford seeks discretionary review asserting insufficiency of the evidence under Article 62.055(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence under 62.055(a).	Ford contends no proof of intended address change to a new address.	State contends evidence of living at a new address supports intent to change.	Evidence insufficient to prove a specific intended address change; conviction reversed? Actually affirmed per opinion: Court affirmed.

Thomas v. State, 444 S.W.3d 4 (Tex. Crim. App. 2014) (indicates moving evidence supports intent to change address)
Gilder v. State, 469 S.W.3d 636 (Tex. App.-Houston [14th Dist.] 2015) (discussed addressing sufficiency post-Thomas)
Green v. State, 350 S.W.3d 617 (Tex. App.-Houston [14th Dist.] 2011) (discussed effect of living at new address on reporting)