Cortez v. State (1979)
In Cortez v. State, 582 S.W.2d 119 (Tex.Crim.App.1979), the defendant paid for window tinting with an insufficient-funds check and was convicted of theft by check of services.
The Court of Criminal Appeals reversed, finding that the statute requires a deceptive act which affects the judgment of another.
Because defendant's sole deceptive act was paying with an insufficient-funds check after his windows had been tinted, the check could not have affected the vendor's judgment. Id. at 120-21.