Court of Criminal Appeals of Texas
Elmer Lavaughn Freeman, Appellant v. the State of Texas, Appellee
March 9, 19831983 Tex. Crim. App. LEXIS 930
Summary
The Court reversed Freeman's conviction for theft, holding that the circumstantial evidence was insufficient to prove he was a party to the crime under Penal Code §7.02, and affirmed that the standard of appellate review for sufficiency of evidence is whether any rational trier of fact could find guilt beyond a reasonable doubt, regardless of whether the evidence is direct or circumstantial. Justice McCORMICK concurred, emphasizing that the exclusion‑of‑reasonable‑hypotheses analysis is not part of the ultimate standard.