Trayvon Tyrone May v. the State of Texas

CourtTexas Court of Appeals, 1st District (Houston)
DecidedFebruary 24, 2026
Docket01-24-00406-CR
StatusPublished

This text of Trayvon Tyrone May v. the State of Texas (Trayvon Tyrone May v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 1st District (Houston) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trayvon Tyrone May v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

Opinion issued February 24, 2026

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-24-00404-CR NO. 01-24-00406-CR ——————————— TRAYVON TYRONE MAY, Appellant V. THE STATE OF TEXAS, Appellee

On Appeal from the 21st District Court Washington County, Texas Trial Court Case Nos. 19474, 19475

MEMORANDUM OPINION

Appellant Trayvon Tyrone May was convicted for evading arrest and two

counts of aggravated assault against a public servant. He appeals his convictions for aggravated assault,1 contending the evidence is insufficient to support the mens rea

element of the offenses. We affirm

Background

While on patrol, Officer Armando Guerra of the Brenham Police Department

noticed a red Dodge Durango with a missing front license plate and a covered rear

license plate. Officer Guerra decided to make a traffic stop. As he accelerated to

catch up with the Durango, which Appellant was driving, Officer Guerra witnessed

Appellant speed and change lanes without signaling. Officer Guerra activated his

emergency lights, and Appellant pulled over without any trouble.

Officer Guerra approached on the passenger side and “smelled fresh

marijuana in the car.” Appellant identified himself to Officer Guerra and admitted

that he did not have a driver’s license or insurance. Officer Guerra asked Appellant

to step out of the Durango, and they talked while standing next to the patrol car.

When asked, Appellant initially denied having marijuana but eventually admitted to

there being a small amount in the Durango’s center console. Officer Guerra decided

to search the Durango and called for backup. Corporal Andrea Guerra arrived to

assist.

1 Appellant also appeals his evading-arrest conviction but does not challenge that conviction in his briefing. Accordingly, we affirm that conviction. 2 Appellant continued to stand near the patrol car while Officer Guerra searched

the Durango and found the marijuana Appellant had disclosed. During the search,

Officer Guerra learned from dispatch that the rear license plate did not match the

Durango, leading him to believe it might be stolen. Officer Guerra arrested

Appellant for possession.

Officer Guerra described Appellant as “polite” up to this point. But when

Officer Guerra took Appellant into custody, Appellant gave “a little resistance.” As

Officer Guerra placed Appellant in the rear seat of the patrol car, Appellant kept his

legs outside of the car and began to stall. After being told by Officer Guerra that the

rear license plate did not match the Durango, Appellant managed to free one hand

from the handcuffs and pushed past Officer Guerra and Corporal Guerra.

Appellant succeeded in getting by the officers and into the Durango’s driver’s

seat. As described more fully below, Officer Guerra and Corporal Guerra struggled

with Appellant as he tried to put the Durango into gear, which he eventually

succeeded in doing. Officer Guerra and Corporal Guerra fell to the ground as the

Durango moved and believed Appellant was trying to run them over. The defense

claimed Appellant’s movements in the Durango were to avoid a civilian bystander’s

3 truck which the bystander had parked in front of the Durango to block Appellant’s

exit.2

As Appellant drove away, Officer Guerra rose to his knees, drew his sidearm,

and fired twice in Appellant’s direction but did not hit him. Both officers returned

to their patrol cars and pursued Appellant for a few miles before losing sight of him.

The pursuit was called off, but Appellant was later arrested after crashing the

Durango.

Appellant was charged with evading arrest and multiple counts of aggravated

assault against a public servant with a deadly weapon. A jury convicted him of

evading arrest and two counts of aggravated assault based on threatening the officers

with imminent bodily injury while using or exhibiting a deadly weapon. Appellant

was sentenced to ten years’ confinement for evading arrest and thirty years’

confinement for each aggravated-assault count, all sentences to run concurrently.

Appellant now appeals.

2 The civilian testified that he was driving when he saw Appellant fighting with Officer Guerra. The civilian decided to stop and assist by blocking Appellant’s Durango from the front.

4 Sufficiency of Evidence

In a single appellate issue, Appellant argues the evidence is insufficient to

support the jury’s finding that he intentionally or knowingly committed the assaults

forming the basis of the aggravated-assault offenses.

A. Standard of review

The State must prove each essential element of an offense beyond a reasonable

doubt. Baltimore v. State, 689 S.W.3d 331, 340 (Tex. Crim. App. 2024); see also

Jackson v. Virginia, 443 U.S. 307, 318–19 (1979). The sufficiency of the State’s

evidence “is measured by comparing the evidence produced at trial to ‘the essential

elements of the offense as defined by the hypothetically correct jury charge.’”

Curlee v. State, 620 S.W.3d 767, 778 (Tex. Crim. App. 2021) (quoting Malik v.

State, 953 S.W.2d 234, 240 (Tex. Crim. App. 1997)). We consider all the admitted

evidence and view it in the light most favorable to the verdict. Harrell v. State, 620

S.W.3d 910, 913–14 (Tex. Crim. App. 2021); Winfrey v. State, 393 S.W.3d 763, 767

(Tex. Crim. App. 2013). We then determine whether the cumulative force of the

evidence, together with any reasonable inferences from it, could lead a rational juror

to find that the State has proven the essential elements of the crime beyond a

reasonable doubt. Baltimore, 689 S.W.3d at 341; see also Cary v. State, 507 S.W.3d

761, 766 (Tex. Crim. App. 2016) (appellate court’s role is not to act as additional

5 juror but to ensure jury’s verdict is rational one based on more than “a mere modicum

of evidence”).

As the sole factfinder, the jury may believe some witnesses, disbelieve others,

weigh the evidence, and reasonably infer facts therefrom. See Canfield v. State, 429

S.W.3d 54, 65 (Tex. App.—Houston [1st Dist.] 2014, pet. ref’d). In drawing

inferences, juries may “use common sense and apply common knowledge,

observation, and experience gained in ordinary affairs.” Acosta v. State, 429 S.W.3d

621, 625 (Tex. Crim. App. 2014). But juries may not “come to conclusions based

on mere speculation or factually unsupported inferences or presumptions.”

Baltimore, 689 S.W.3d at 342.

B. Analysis

As charged in this case, a person commits the first-degree felony of

aggravated assault on a public servant by threat when (1) he commits assault by

“intentionally or knowingly threaten[ing] another with imminent bodily injury,”

(2) he “uses or exhibits a deadly weapon during the commission of the assault,” and

(3) the offense is committed “against a person the actor knows is a public servant

while the public servant is lawfully discharging an official duty.” See TEX. PEN.

CODE §§ 22.01(a)(2), .02(a)(2), (b)(2)(B). A threat need not be verbal; a person may

communicate a threat by action or conduct. McGowan v. State, 664 S.W.2d 355

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Landrian v. State
268 S.W.3d 532 (Court of Criminal Appeals of Texas, 2008)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
McGowan v. State
664 S.W.2d 355 (Court of Criminal Appeals of Texas, 1984)
Winfrey, Megan AKA Megan Winfrey Hammond
393 S.W.3d 763 (Court of Criminal Appeals of Texas, 2013)
Acosta, Victor Manuel
429 S.W.3d 621 (Court of Criminal Appeals of Texas, 2014)
Jonathan D. Canfield v. State
429 S.W.3d 54 (Court of Appeals of Texas, 2014)
Cary v. State
507 S.W.3d 761 (Court of Criminal Appeals of Texas, 2016)

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Trayvon Tyrone May v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trayvon-tyrone-may-v-the-state-of-texas-txctapp1-2026.