Randall Seigler v. State
07-15-00047-CR
| Tex. App. | Aug 21, 2015Background
- On July 3, 2014, Jerry Ray discovered that 350 MCM THHN copper cable had been cut from a conduit at Ray’s Electric; value estimated $350–$500 and no consent was given.
- Ray observed a person in a white shirt and red pants inside the storage yard, crawling through a hole in the chain‑link fence, and later identified appellant Randall Seigler as that person at trial.
- Police found drag marks from the hole into the adjacent alley, the copper wire in weeds, and large bolt cutters in the alley; a shoeprint was photographed at the fence hole.
- A K‑9 tracked scent from the hole to a vacant lot where officers found Seigler wearing a white shirt and red sweat pants; he had wire cutters with copper shavings and a flashlight, and his shoe tread matched the print at the scene.
- Seigler was charged with theft of copper (< $20,000) with two prior felony enhancements; the trial court denied his motion for directed verdict after the State’s case, a jury found him guilty and true on enhancements, and he was sentenced to 20 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying a directed verdict (sufficiency of the evidence) | State: Circumstantial and direct evidence (identification, K‑9 track, tool with copper shavings, shoe match, drag marks) was sufficient to prove theft beyond a reasonable doubt | Seigler: Evidence was insufficient; he was not seen with the copper and proof was largely circumstantial | Court: Evidence (including circumstantial) was sufficient under Jackson/Brooks; denial of directed verdict proper; conviction affirmed |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (application of Jackson standard in Texas and deference to jury credibility determinations)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence can support conviction)
- Canales v. State, 98 S.W.3d 690 (Tex. Crim. App.) (directed‑verdict claim reviewed as sufficiency challenge)
- Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (sufficiency measured against a hypothetically correct jury charge)
- Curry v. State, 30 S.W.3d 394 (Tex. Crim. App. 2000) (elements authorized by the indictment define the law for sufficiency review)
- Watson v. State, 204 S.W.3d 404 (Tex. Crim. App. 2006) (discussion of standards for appellate sufficiency review)