Juan Jose Sanchez v. State, 01-17-00011-CR

Juan Jose Sanchez was convicted by a jury of two counts of fraudulent use of identifying information under Tex. Penal Code § 32.51(b)(1); punishment in each count: two years confinement, probated for two years.
The State alleged Sanchez negotiated two checks drawn on Kim Pham’s joint checking account, both dated August 27, each for $375, payable to Juan Jose Sanchez and bearing Kim Pham’s purported signature with the memo "Gutter Repair."
The checks were negotiated on different dates (September 8 and 9) at different bank branches; bank records and surveillance identified Sanchez as the person who cashed them.
Kim and her husband Thai Pham testified they never wrote or authorized the checks, had not hired Sanchez, did not know him, and had not had gutter work performed; their check numbering at the time made the negotiated check numbers inconsistent with their usage.
Detective Fields authenticated the bank surveillance images and Sanchez’s identification; no evidence showed how Sanchez obtained the checks or whether they were stolen, and there was no evidence Sanchez performed any services for the Phams.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that defendant intended to defraud or harm	The State: circumstantial evidence (unauthorized checks, denial by Phams, surveillance ID) supports an intent to defraud	Sanchez: no proof how he obtained checks, no evidence Phams’ checks were stolen, presenting checks under his own name suggests belief they were genuine	Court affirmed: cumulative circumstantial evidence permitted a rational jury to infer intent to defraud or harm

Jackson v. Virginia, 443 U.S. 307 (legal sufficiency standard)
Gear v. State, 340 S.W.3d 743 (Tex. Crim. App. 2011) (apply Jackson standard)
Pena v. State, 441 S.W.3d 635 (Tex. App.—Houston [1st Dist.] 2014) (application of sufficiency review)
Isassi v. State, 330 S.W.3d 633 (Tex. Crim. App. 2010) (deference to jury credibility findings)
Ramsey v. State, 473 S.W.3d 805 (Tex. Crim. App. 2015) (circumstantial evidence probative; State not required to disprove exculpatory inferences)
Ledesma v. State, 677 S.W.2d 529 (Tex. Crim. App. 1984) (intent inferred from actions and circumstances)
Tottenham v. State, 285 S.W.3d 19 (Tex. App.—Houston [1st Dist.] 2009) (intent may be proven circumstantially)
Burks v. State, 693 S.W.2d 932 (Tex. Crim. App. 1985) (intent can be proven by circumstantial evidence)
Grimm v. State, 496 S.W.3d 817 (Tex. App.—Houston [14th Dist.] 2016) (elements of § 32.51(b)(1) include intent to harm or defraud)