Griffin v. State

In Griffin v. State, 908 S.W.2d 624 (Tex. App.--Beaumont 1995, no pet.), the Court reversed the conviction and ordered acquittal of a defendant convicted of forgery, finding the evidence legally insufficient to prove he intended to "defraud or harm another" when he presented a forged check made payable to him. Id. at 626, 628. As the Court noted, in a forgery case, the culpable mental state requires proof of knowledge that the check is forged, and if the State proves that an actor has knowledge that a particular check is forged, proof of intent to defraud is inferred. Id. at 627. In Griffin, after we reviewed the record evidence for "knowledge" of the forgery, we looked to other cases addressing the issue and noted that "in each opinion sustaining a forgery conviction, there has been some additional evidence of 'suspicious circumstances' which show that the defendant knowingly and intentionally passed the forged check." Griffin, 908 S.W.2d at 627.