John David Najera v. State
John David Najera appealed his conviction for theft of service, arguing the State failed to prove statutory notice of demand for payment was sent with a return receipt requested as mandated by Texas Penal Code Section 31.04(c). The Labor Justice Committee, acting on behalf of the complainant Esteban Rangel, sent a demand letter to Najera. Although the letter indicated a return receipt was requested, evidence including the postal service receipt and testimony confirmed it was sent via certified mail without a return receipt. The court found this a critical deficiency, as the statute explicitly requires a return receipt. Consequently, the appellate court reversed the trial court's judgment and rendered a judgment of acquittal due to legally insufficient evidence.