Hal Wayne Honea v. the State of Texas, 11-19-00319-CR

Hal Wayne Honea (appellant), a convicted sex offender, was indicted for failing to register in Cisco, Texas after residing there for more than seven days, with two prior-felony enhancements; he waived jury trial and received 30 years.
DPS Special Agent Graham conducted a compliance check after reports Honea lived in Cisco; Honea initially said he and his wife lived in an RV in Breckenridge but later admitted spending substantial time at his wife’s house in Cisco.
Evidence the State relied on: Honea’s statements in pre-/post-polygraph interviews admitting noncompliance and that he spent ~70% of April in Cisco; cell-phone location records showing multiple days of activity only in Cisco; neighbor testimony observing Honea’s truck and overnight presence; few personal effects in the RV; a handwritten apology letter.
Defense witnesses (mother, wife, children) testified Honea’s principal residence was with his mother in Breckenridge and that any Cisco stays were for work or brief visits to prepare/sell the house.
The indictment charged a specific statutory theory: violation of Art. 62.051(a) — residing in Cisco for more than seven days without registering — which limited the State to proving that manner of violation.
Honea also argued on appeal that the Chapter 62 registration scheme is unconstitutionally vague as applied to him; the trial court never ruled on vagueness at trial but Honea raised it in his motion for new trial.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Honea)	Held
Sufficiency: whether evidence proves Honea resided in Cisco >7 days and failed to register	Admissions, phone records, neighbor observations, RV evidence, and apology letter suffice to prove residency, knowledge, and noncompliance	testimony showing Honea lived with his mother in Breckenridge; Cisco stays were transient/work-related and under seven days	Affirmed — viewing evidence cumulatively, a rational factfinder could find residency >7 days and knowing failure to register
Vagueness: whether Chapter 62 is unconstitutionally vague as applied	Statute gives fair notice and specific procedures; Honea knew registration duties; issue was not properly preserved for trial	Statute is vague about registration for multiple/simultaneous residences and failed to give clear notice	Overruled — court finds issue not preserved; even on merits, statute not unconstitutionally vague as applied

Jackson v. Virginia, 443 U.S. 307 (established the legal-sufficiency standard for criminal convictions)
Brooks v. State, 323 S.W.3d 893 (deference to factfinder on credibility and sufficiency review under Jackson)
Geick v. State, 349 S.W.3d 542 (indictment limits the method of proving an offense when statute lists alternatives)
Robinson v. State, 466 S.W.3d 166 (culpable mental states apply to duty-to-register element)
Febus v. State, 542 S.W.3d 568 (Article 62.102 offenses treated as circumstances-of-conduct offenses)
Whitney v. State, 472 S.W.2d 524 (residence requires more than mere lodging; may be temporary but must show more than overnight stays)
Winfrey v. State, 393 S.W.3d 763 (consider all evidence in sufficiency review, defer to factfinder)
Hooper v. State, 214 S.W.3d 9 (circumstantial evidence may suffice to prove guilt)