Randall Joseph Lewis v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 11, 2025
Docket08-24-00387-CR
StatusPublished

This text of Randall Joseph Lewis v. the State of Texas (Randall Joseph Lewis v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Randall Joseph Lewis v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS ————————————

No. 08-24-00387-CR ————————————

Randall Joseph Lewis, Appellant

v.

The State of Texas, Appellee

On Appeal from the 144th District Court Bexar County, Texas Trial Court No. DC2024CR1984

M E MO RA N D UM O PI NI O N 1

Appellant Randall Joseph Lewis appeals his conviction of unlawful possession of a firearm

by a felon. Finding no error, we affirm.

1 This case was transferred pursuant to the Texas Supreme Court’s docket equalization efforts. Tex. Gov’t Code Ann. § 73.001. We follow the precedent of the Fourth Court of Appeals to the extent it might conflict with our own. See Tex. R. App. P. 41.3. I. BACKGROUND In November 2023, Stacie Lewis called 911 and reported that Lewis, her nephew, came to

her home with a gun. Because Lewis had a previous felony conviction, he was arrested and charged

with unlawful possession of a firearm by a felon. At trial, the State presented evidence of his prior

conviction, the audio of the 911 calls, the testimony of Stacie and San Antonio Police Officer

Timothy Clark, and Clark’s body camera video. The State did not offer the firearm into evidence.

The jury found Lewis guilty and, because of two habitual offender enhancement findings,

sentenced him to 25 years.

In two issues, Lewis challenges the sufficiency of the evidence to support his conviction

under (1) the due process clause of the United States Constitution and (2) the due process clause

of the Texas Constitution. ANT 9 U.S. Const. amend. V, XIV; Tex. Const. art. I § 19. Because we

review the legal sufficiency of the evidence under one standard, we address both issues as one.

Brooks v. State, 323 S.W.3d 893, 895 (Tex. Crim. App. 2010) (holding that sufficiency of the

evidence is reviewed under one standard).

II. ANALYSIS

A. Standard of review

It is “the responsibility of the trier of fact to fairly resolve conflicts in testimony, to weigh

the evidence, and to draw reasonable inferences from basic facts to ultimate facts.” Hooper v. State,

214 S.W.3d 9, 13 (Tex. Crim. App. 2007) (quoting Jackson v. Virginia, 443 U.S. 307, 318–19

(1979)). To that end, in a legal sufficiency review “we consider all the evidence in the light most

favorable to the verdict and determine whether, based on that evidence and reasonable inferences

therefrom, a rational juror could have found the essential elements of the crime beyond a

reasonable doubt.” Id.

2 B. Unlawful possession of a firearm

A person who has been convicted of a felony and released from confinement or supervision

more than five years ago commits the offense of unlawful possession of a firearm if he possesses

the firearm at “any location other than the premises at which the person lives.” Tex. Penal Code

Ann. § 46.04(a)(2). Because the statute does not include a culpable mental state, “intent,

knowledge, or recklessness suffices to establish criminal responsibility.” Tex. Penal Code Ann.

§6.02(b), (c). An offense is committed intentionally if it is the actor’s “conscious objective or desire

to engage in the conduct or cause the result.” Id. § 6.03(a). It is committed knowingly if the actor

“is aware of the nature of his conduct or that the circumstances exist.” Id. §6.03(b). And an offense

is committed recklessly when the actor “is aware of but consciously disregards a substantial and

unjustifiable risk that the circumstances exist or the result will occur.” Id. §6.03(c).

C. Sufficiency of the evidence

Lewis does not dispute that he was convicted of a felony in 2010 and sentenced to 180 days

in jail or that he did not live at his aunt and uncle’s house (which would have permitted him to

lawfully possess a gun there). Lewis challenges the sufficiency of the evidence to show (1) that

the gun was in fact a firearm, (2) that he possessed a firearm, and (3) that that he had the necessary

mens rea.

(1) Evidence of a firearm

Lewis points out that the State did not offer the gun into evidence. There is no requirement

that the weapon be in evidence so long as there was other sufficient evidence from which a juror

could find that a firearm was involved. See, e.g., Hutchings v. State, 333 S.W.3d 917, 920

(Tex. App.—Texarkana 2011, pet. ref’d) (finding sufficient evidence of unlawful possession of a

firearm based on witnesses’ testimony about the firearm); Tapps v. State, 257 S.W.3d 438, 446

(Tex. App.—Austin 2008), aff’d, 294 S.W.3d 175 (Tex. Crim. App. 2009) (same). Stacie testified

3 that she saw Lewis take a gun out of his jeans and place it on a table in her garage. Clark’s body

camera also captured video of the gun when Clark picked it up to inspect it. Even without

admission of the gun in evidence, a rational juror could believe the testimony that a gun was

present.

Lewis also argues that the State did not present any evidence showing that the handgun

was examined to “verify that it was, in fact, a weapon.” In offenses involving the possession or

use of a firearm, the State has no burden to prove that the firearm was a real, instead of a fake or

inoperable, weapon. Ramos v. State, No. 03-24-00350-CR, 2025 WL 2677894, at *5 (Tex. App.—

Austin Sept. 19, 2025, no pet. h.) (mem. op., not designated for publication) (citing Porter v. State,

601 S.W.2d 721, 723 (Tex. Crim. App. 1980) and Leadon v. State, 332 S.W.3d 600, 610

(Tex. App.—Houston [1st Dist.] 2010, no pet.)).

There was sufficient evidence that the item that Lewis put in Stacie’s garage was a firearm.

(2) Evidence of possession

Lewis argues that the evidence that he possessed the firearm was legally insufficient

because it consisted solely of one witness’s statements to law enforcement and testimony. Stacie’s

husband, Lewis’s uncle, did not testify although he was there that night and it was he whom Lewis

asked to take the firearm. Nor did the police witness Lewis with a gun. When Officer Clark arrived,

the gun was sitting on a table and Clark admitted that he never saw Lewis with the gun. Finally,

there was no evidence that Lewis admitted to possessing the gun.

The testimony of one eyewitness can be sufficient to support a verdict. Aguilar v. State,

468 S.W.2d 75, 77 (Tex. Crim. App. 1971); Castilla v. State, 374 S.W.3d 537, 539 (Tex. App.—

San Antonio 2012, pet. ref’d). Although the State could have called Lewis’s uncle to testify, it was

not required to do so. “[T]he State has the right to prove its case in any way it may see fit under

proper rules and regulations, and an accused cannot be allowed to direct either the method or

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Porter v. State
601 S.W.2d 721 (Court of Criminal Appeals of Texas, 1980)
Aguilar v. State
468 S.W.2d 75 (Court of Criminal Appeals of Texas, 1971)
Tapps v. State Tex.
257 S.W.3d 438 (Court of Appeals of Texas, 2008)
Manning v. State
730 S.W.2d 744 (Court of Criminal Appeals of Texas, 1987)
Gonzales v. State
466 S.W.2d 772 (Court of Criminal Appeals of Texas, 1971)
Tapps v. State
294 S.W.3d 175 (Court of Criminal Appeals of Texas, 2009)
Hutchings v. State
333 S.W.3d 917 (Court of Appeals of Texas, 2011)
Leadon v. State
332 S.W.3d 600 (Court of Appeals of Texas, 2010)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Lantrip v. State
336 S.W.3d 343 (Court of Appeals of Texas, 2011)
Chambers v. State
805 S.W.2d 459 (Court of Criminal Appeals of Texas, 1991)
Michael Castilla v. State
374 S.W.3d 537 (Court of Appeals of Texas, 2012)

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