Ramsey, Donald Lynn A/K/A Donald Lynn Ramsay, PD-0070-15

Defendant Donald Lynn Ramsey was convicted by a jury of forgery by passing a $65 check drawn on Owens Motor Machine and payable to Ramsey, enhanced for an elderly victim; sentence: 6 years and $1,000 fine.
Facts: the check bore the signature "Jim E. Owens" and memo "Contract Labor." Owens (Jimmie) and his son Jed were account signatories; Jimmie normally signed as "J.E. Owens" or "Jimmie E. Owens." Ramsey lived at the shop, had access to an unlocked truck where the checkbook was kept, and was the business’s only employee for months prior.
Ramsey cashed the check at a nearby liquor store that had previously been authorized to cash his paychecks; neither Jimmie nor Jed signed or authorized the check.
The court of appeals (majority) reversed and rendered acquittal, holding the State failed to prove Ramsey knew the check was forged — the majority found no evidence Ramsey knew the signature was not genuine and required more proof (e.g., number of prior checks, specific signature practice) to infer knowledge.
A dissenting appellate judge argued the circumstantial evidence (beneficiary status, near-exclusive access to the checkbook, memo indicating payment for labor not performed, choice of venue to avoid scrutiny) supported an inference Ramsey knew the check was forged.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Ramsey)	Held
Sufficiency of evidence that defendant knew the writing was forged (intent to defraud or harm)	Facts and reasonable inferences (beneficiary, near-exclusive access to checkbook, memo for "Contract Labor," cashed where paychecks are cashed) permit a jury to infer Ramsey knew the check was forged	No direct evidence that Ramsey knew signature was forged; possession/passage of payable-to-self check and access to checkbook insufficient to prove knowledge	Court of Appeals (majority) reversed and entered acquittal for insufficiency of evidence; dissent would have upheld conviction on circumstantial evidence

Jackson v. Virginia, 443 U.S. 307 (supreme‑court standard for reviewing sufficiency of evidence — view evidence in light most favorable to verdict)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App.) (discusses modern sufficiency review framework)
Okonkwo v. State, 398 S.W.3d 689 (Tex. Crim. App. 2012) (intent to defraud/harm in forgery can be shown by knowledge the writing was forged)
Stuebgen v. State, 547 S.W.2d 29 (Tex. Crim. App. 1977) (forging employee case: possession/passing and access insufficient to prove knowledge of forgery)
Williams v. State, 688 S.W.2d 486 (Tex. Crim. App. 1985) (circumstantial statements can support an inference of knowledge/intent)
Crittenden v. State, 671 S.W.2d 527 (Tex. Crim. App. 1984) (forgery sufficiency principles; reversal where knowledge not established)