Robbing An Undercover Police Officer Case In Texas
In Lane v. State, 933 S.W.2d 504, 507 (Tex. Crim. App. 1996), the Court of Criminal Appeals reversed a lower court's finding of insufficient evidence to convict Lane of robbing an undercover police officer. Id. at 788.
The officer was posing as a stranded motorist, and Lane tried to grab the officer's wallet, which she was holding in her hand.
The officer jerked back and pulled the wallet to her, but Lane grabbed the wallet with both hands, twisted it, took it, and ran. the officer sustained bruises on her wrists.
The court said the issue was whether Lane acted knowingly, i.e., whether he was at least aware that bodily injury would result from his conduct.
The court proceeded to determine whether, in twisting the officer's wrist to obtain her wallet, Lane at least was reasonably certain he would cause her bodily injury. the court observed:
Establishment of culpable mental states is almost invariably grounded upon inferences to be drawn by the factfinder from the attendant circumstances . . . . the threshold of proof necessary to support a jury finding of an awareness that [bodily injury] is reasonably certain to occur is concomitantly low. Lane v. State, 763 S.W.2d at 787.
The court held that the jury could have reasonably inferred from the force in Lane's conduct that he was at least aware that his conduct was reasonably certain to cause physical pain, and therefore, bodily injury.