Property Owners Testimony Alone May Satisfy Loss Element of Criminal Mischief Offense

An overdue apology to our readers out there.  As the tempo of my day job increases, my posting of Texas criminal law news and cases decreases.  Although I doubt there is anyone waiting by their computer for me to post about breaking Texas cases, I apologize for my apathy nonetheless.  However, today is not the day that I resume substantive and continuous posting. 

Here's a blurb (a cut and paste, actually) about a recent CCA opinion regarding the evidence required to prove penuciary loss element of a criminal mischief offense.

Holz v. State: 

A person commits the offense of criminal mischief when she intentionally or knowingly damages or destroys tangible property without the effective consent of the owner.  The amount of pecuniary loss suffered by the owner determines the degree of the offense.  If the property is damaged (as opposed to destroyed) the amount of pecuniary loss is determined by “the cost of repairing or restoring the damaged property within a reasonable time after the damage occurred.”

The question presented was whether, in order to prove the pecuniary loss element of a criminal mischief offense, a non-expert property owner's testimony about the cost of repairing or restoring his damaged property can be sufficient without further evidence?

Reversing the judgment of the 6th District Court of Appeals and clairfying the it prior holding in Elomary v. State, 796 S.W.2d 191 (Tex. Cr. App. 1990), the CCA held that expert testimony is not required to prove the pecuniary loss element and that a non-expert property owner's testimony may be sufficient, even standing alone.