In Pyka v. Texas, 80 Tex. Crim. 644, 192 S.W. 1066, 1067 (Tex. Ct. Crim. App. 1917), the defendant had picked up a pistol on the ground, hit his opponent with it, and thrown it back down. Following 14 cases in which the Texas courts held that similarly brief and unplanned possession of a weapon did not constitute "carrying" the weapon, the Texas Court of Criminal Appeals held that proof of such acts was insufficient to sustain the defendant's conviction for carrying a pistol on his person. See id.