Juan Ismael Sanchez v. State
521 S.W.3d 817
| Tex. App. | 2017Background
- Sanchez was convicted by a jury of theft of a 2000 Volkswagen Beetle (state jail felony for property >= $1,500 and < $20,000) and later pleaded true to prior-felony enhancements; punishment assessed at 12 years.
- The defense rested without calling witnesses; Sanchez appealed claiming insufficient evidence of the vehicle’s fair market value.
- Owner Laura Loera testified she purchased the Beetle for $3,500 but did not state when she purchased it; a photograph of a similar, apparently good-condition Beetle was admitted.
- Deputy K. Reed testified he researched car values using Kelley Blue Book and opined the Beetle’s value exceeded $1,500 but was under $20,000; he had not seen the actual vehicle.
- Sanchez argued Loera’s testimony lacked temporal context and Reed was unqualified and failed to expressly state “fair market value”; he did not object to Reed’s qualifications at trial.
- The court evaluated sufficiency under Jackson v. Virginia and concluded the combined owner and officer testimony was sufficient for a rational juror to find the car’s fair market value met the statutory threshold.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence of vehicle fair market value | State: Owner’s purchase price plus officer’s Kelley Blue Book-based testimony shows value ≥ $1,500 | Sanchez: Owner didn’t state when she bought the car; officer was unqualified, hadn’t seen the car, and didn’t state "fair market value" | Affirmed: Combined testimony sufficient for a rational juror to find value ≥ $1,500 and < $20,000 |
| Admissibility/qualification of non-owner valuation testimony | State: Officer’s Kelley Blue Book research supports value opinion | Sanchez: Officer’s qualifications and basis not established at trial | Error not preserved—no trial objection; officer’s testimony admissible for sufficiency review |
| Whether owner must state purchase date to support value | State: Owner’s purchase price can support fair market value | Sanchez: Lack of purchase date undermines value inference | Court: Owner’s purchase-price testimony, without temporal context, was weak but not fatal given officer testimony |
| Requirement that expert use phrase “fair market value” | State: Expert need not use that exact phrase if testifying to cash value via KBB | Sanchez: Officer didn’t explicitly say “fair market value” | Court: Literal phrase not required; officer’s KBB-based cash-value opinion sufficed |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
- Gear v. State, 340 S.W.3d 743 (Tex. Crim. App.) (applying Jackson standard)
- Keeton v. State, 803 S.W.2d 304 (construing "fair market value" and methods to prove it)
- Sullivan v. State, 701 S.W.2d 905 (owner may testify to value; ownership testimony generally presumed to concern fair market value)
- Moff v. State, 131 S.W.3d 485 (preservation rule for objections to valuation method or witness qualifications)
- Cooper v. State, 537 S.W.2d 940 (expert may rely on Kelley Blue Book for vehicle value)
- Thomas v. State, 621 S.W.2d 158 (non-owner expert need not inspect the particular property to opine on value)