Whether Texas courts are applying the 'absurdity doctrine' in a manner that violates due process and whether Jackson v. Virginia allows jurors to rely on outside knowledge to secure a conviction

In 1895, Justice Harlan, writing for the Court explained, [n]o man should be deprived of his life under the forms of law unless the jurors who try him are able . . . to say that the evidence before them . . . existence of every fact necessary to constitute the crime charged . Davis v. United States , 160 U.S. 469, 493, 16 S. Ct. 353, 360, 40 L. Ed. 499 (1895). (emphasis added). Understandably, this Court continues to adhere to this basic principle. See In re Winship , 397 U.S. 358, 363, 90 S. Ct. 1068, 1072, 25 L. Ed. 2d 368 (1970). Yet, here, the reviewing court rejected this principle on the ground the Texas Legislature could not have intended to write the statute as they did. Rodgers v. State , No. 05-2300316-CR, 2024 WL 3158161, at *5 (Tex. App.—Dallas June 25, 2024, pet. ref’d). This remarkable decision relieved the State of the responsibility of proving one required element and violated Petitioner’s due-process rights. Id. Separately, the reviewing court found “common at *4-*5. The “common knowledge” the reviewing court relied on (that most cars in Texas must be registered) is generally true but exceptions exist. See Tex. Trans. Code Ann. §§ 502.140(b), 502.141, 502.142, 502.144, 502.145(a), 502.146(b)-(e). The Texas court recognized the exceptions but allowed the general rule to govern without knowledge of whether any of the exceptions applied. Rodgers , 2024 WL 3158161, at *5 n.2. Does Jackson v. Virginia tolerate such an approach? The questions presented are:Whether Texas courts are applying the “absurdity doctrine” in a manner that violates due process? ii Whether Jackson v. Virginia tolerates inferences based on knowledge from outside the evidence and if so whether those inferences are allowable if they are generally but not always correct?