Appellate Brief Scenario:

Your client, Mr. Sammy Savage, stands convicted under TEXAS state law for charges involving theft, trafficking in stolen property, fraud, and alteration of vehicle identification numbers.

Sammy Savage runs a small salvage yard on a 3.5 acre piece of property

surrounded by several fences, tall trees, dense scrub bushes, and posted No Trespassing

signs. The property contains 2 structures: a small one-room cabin, in which Mr.

Savage resides, and a separate structure, approximately 30 feet high, with sliding

barn doors on all four sides, no windows, and no roof.

Early on the day of Mr. Savages arrest, state and local authorities

conducted a drone-surveillance sweep after an anonymous tip line received several

calls reporting the operation of multiple automotive chop shops in a rural location

within the State of Texas and captured video of the larger structure, obtained by

the drone's camera from approximately 100 feet in the air and simultaneously transmitted

to police officers on the ground, revealed the presence of multiple dismantled vehicles,

a pile of license plates, various automotive parts and tools, including grinders,

cutting saws, hoists and welding rigs. Mr. Savage was taken into police custody

at approximately 6:00 a.m. that morning, and was subsequently charged based on that

footage.

At trial, several residents claimed that the presence of the drones

in the early morning hours resulted in unnecessary panic, which quickly swept the

small community, and resulted in multiple calls to local police dispatch, some minor

property damage, and at least one assault. Nacy Nosey, who lives adjacent to Ms.

Mr. Savage, testified that, "David Dickerson and those damned drones caused enough

drama and paranoia to end a 25-year friendship in a fistfight." David Dickerson,

a survivalist/prepper and avid short-wave radio enthusiast, stated for the record

that, on the morning of Mr. Savage's arrest, he was up late monitoring radio transmissions

between members of a known local anti-government group who were discussing plans

for "something big" involving the use of personal drones. Mr. Dickerson stated that

he heard an unusual buzzing noise coming from the west side of his property as he

stood outside with his dog at approximately 4:00 a.m. When he spotted a drone hovering

between his house and his garage, he immediately began calling to warn his neighbors

that something was up, and to remain vigilant.

The trial court considered all testimony, exhibits, and arguments and found your client guilty.

Question:

Locate and correctly cite for TEXAS

1. At least one source of primarylegal authorityfromTexas.

2. At least one source of persuasive authority; this may be secondary or primary, but not mandatory for TEXAS