State Ex Rel. Tc, 60 So. 3d 1260

T.C. was adjudicated delinquent for unauthorized use of a motor vehicle after a July 4, 2008 incident.
Officer Tiwana Alexander stopped a vehicle believed stolen; T.C. provided name, DOB, SSN, and address but no ID, claiming the car and keys came from his cousin Torey C.
Ms. Lucinda Lawson testified she owned the 2001 Chevrolet Malibu, reported it stolen, and did not know T.C.; she did not give permission to Torey C. to use the vehicle.
Evidence at adjudication showed the vehicle had Texas plates, expired tags, and that the key was in the ignition; the trial court accepted State witnesses’ testimony as credible.
The juvenile court found T.C. delinquent and placed him on inactive probation for six months after an initial six-month commitment was suspended.
On appeal, the defense challenged the sufficiency of the evidence to prove beyond a reasonable doubt that T.C. knowingly used a stolen vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proves mens rea for unauthorized use	T.C. knowingly used Lawson's stolen vehicle.	Lack of knowledge the car was stolen negates intent.	Yes, sufficient evidence of mens rea supports delinquency.
Whether driving a stolen vehicle can be proven despite lack of forced entry	Driver’s use when in control proves unauthorized use.	Possession without knowledge of theft could negate intent.	Evidence supports intent; thrust of driving the vehicle satisfies element.

State v. Bias, 400 So.2d 650 (La. 1981) (unauthorized use requires mens rea)
In re H.N., L.C., T.B., 717 So.2d 666 (La.App. 4th Cir. 1998) (reversal where defendant lacked knowledge of theft)
State in the Interest of O.B., 559 So.2d 31 (La.App. 4th Cir. 1990) (no beyond-reasonable-doubt showing of theft knowledge)
State in the Interest of C.B., 28 So.3d 525 (La.App. 4th Cir. 2009) (insufficient evidence that defendant knew vehicle was stolen)
State ex rel. W.B., 11 So.3d 60 (La.App. 4th Cir. 2009) (credibility and weight of evidence within trial court's province)
State ex rel. E.D.C., 903 So.2d 571 (La.App. 2d Cir. 2005) (credibility determinations reside with fact-finder)
State ex rel. T.W., 21 So.3d 465 (La.App. 3d Cir. 2009) (jurisprudence evaluating knowledge of theft in juvenile cases)
Batiste, 367 So.2d 784 (La. 1979) (fundamental sufficiency review standard)
Jones, 537 So.2d 1244 (La.App. 4th Cir. 1989) (conflicting testimony weighs, not necessarily flaws sufficiency)
Vessell, 450 So.2d 938 (La.1984) (credibility of witnesses defers to trial court)
Brumfield, 639 So.2d 312 (La.App. 4th Cir. 1994) (great weight given to trial court’s credibility determinations)
Garner, 621 So.2d 1203 (La.App. 4th Cir. 1993) (appellate review defers to fact-finder on weight of testimony)