Ramsey, Donald Lynn A/K/A Donald Lynn Ramsay, 2015 Tex. Crim. App. LEXIS 1138

Appellant (Ramsey) was convicted of forgery for passing a $65 check payable to himself, drawn on Owens Motor Machine account and signed “Jim E. Owens.”
The check bore “contract labor” in the memo line; the liquor store cashed it because Appellant had previously cashed genuine paychecks there.
Jimmie (age 84) and Jed Owens testified they did not sign or authorize the check; Jed kept a checkbook in his unlocked truck at the shop where Appellant lived and had given Appellant regular access.
Appellant was the payee, a former employee with ready access to the checkbook, and had not performed compensable work supporting the “contract labor” memo.
The court of appeals reversed for insufficient evidence that Appellant knew the check was forged; the State sought review arguing the court misapplied the legal-sufficiency standard.
The Court of Criminal Appeals reversed the court of appeals, holding that under Jackson v. Virginia the cumulative circumstantial evidence permitted a rational jury to infer Appellant knew the instrument was forged and intended to defraud or harm.

Issue	State's Argument	Appellant's Argument	Held
Whether the evidence was legally sufficient to prove Appellant acted with intent to defraud or harm an elderly person by passing a forged check	Circumstantial evidence (beneficiary status, near-exclusive access to checkbook, passing at a place where his paychecks were cashed, memo “contract labor,” lack of any motive for others) permits a rational jury to infer knowledge of forgery and intent	No proof Appellant knew the check was forged: payee status, no handwriting linkage, others had some access, and conflicting testimony (e.g., owner may have forgotten signing) create reasonable alternate hypotheses	Reversed the court of appeals; viewing all evidence in the light most favorable to the verdict, the evidence was sufficient under Jackson to support the jury’s inference that Appellant knew the check was forged and intended to defraud or harm.

Stuebgen v. State, 547 S.W.2d 29 (Tex. Crim. App. 1977) (pre-Jackson precedent on sufficiency in forgery cases relied on alternative-hypothesis reasoning)
Crittenden v. State, 671 S.W.2d 527 (Tex. Crim. App. 1984) (circumstantial-evidence sufficiency analysis in forgery context)
Williams v. State, 688 S.W.2d 486 (Tex. Crim. App. 1985) (forgery case finding circumstantial facts sufficient to infer intent)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for legal sufficiency review: evidence must permit a rational trier of fact to find guilt beyond a reasonable doubt)
Geesa v. State, 820 S.W.2d 154 (Tex. Crim. App. 1991) (disavowed the reasonable-alternative-hypothesis construct for circumstantial-evidence review)
Okonkwo v. State, 398 S.W.3d 689 (Tex. Crim. App. 2013) (to prove intent element in forgery, State must show defendant knew instrument was forged)