Billy Joe McClain v. State, 05-16-00973-CR

Appellant Billy Joe McClain convicted of possession of methamphetamine with intent to deliver and evading arrest; trial court sentenced him to 30 years in each case; convictions affirmed on appeal.
Officers pursued a motorcycle after it fled a traffic stop; driver (appellant) and passenger ran; both were arrested shortly after a ~6-minute, ~4-mile chase.
A backpack thrown off during the chase was recovered and contained items linking appellant to the drugs (marriage certificate, mail addressed to appellant, toothbrush with initials B.J.M.) and drug-distribution paraphernalia (digital scale with residue, 81.57 grams of methamphetamine in a hollowed bottle, baggies with residue, glass pipe, loose pills).
State presented Detective Steve Junker as a narcotics expert to explain methamphetamine production, distribution, usage, pricing, and to opine that the possessor was a dealer who also used the drug.
During qualification/background testimony, Detective Junker described clandestine meth labs, “shake and bake” methods, and stated that such manufacturing had caused people and structures to be "blown up;" defense objected as irrelevant and prejudicial; trial court overruled the objections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether testimony describing meth labs as "blowing up" people/structures was relevant to expert qualification and admissible	State: Background on meth manufacture/labs shows the detective's experience and fit to opine on meth-related matters	McClain: Testimony about explosions and "disastrous" effects was irrelevant to the charged offenses and unfairly prejudicial under Tex. R. Evid. 403	Court: Admissible — the testimony was relevant to the expert's qualifications and provided background context; trial court did not abuse discretion
Whether testimony that ordinary people making meth could be "disastrous" was admissible under Rule 403	State: Same — needed to establish expertise and explain meth landscape (shift to Mexican cartels, dangers of manufacturing)	McClain: Objected only on relevancy at the time; argued prejudicial impact in appellate briefing	Court: Overruled trial objections; even if error, any error was harmless because similar unobjected testimony was admitted elsewhere

Henley v. State, 493 S.W.3d 77 (Tex. Crim. App. 2016) (abuse of discretion standard for evidentiary rulings)
Davis v. State, 329 S.W.3d 798 (Tex. Crim. App. 2010) (two-step inquiry for expert qualifications: background and fit)
Vela v. State, 209 S.W.3d 128 (Tex. Crim. App. 2006) (expert qualification focus on fit between expertise and subject matter)
Miles v. State, 468 S.W.3d 719 (Tex. App.—Houston [14th Dist.] 2015) (admitting background expert testimony not an abuse of discretion), aff'd, 506 S.W.3d 485 (Tex. Crim. App. 2016)
Roy v. State, 997 S.W.2d 863 (Tex. App.—Ft. Worth 1999) (background/context evidence admissible)
Mayes v. State, 816 S.W.2d 79 (Tex. Crim. App. 1991) (background testimony may be more probative than prejudicial)
Gigliobianco v. State, 210 S.W.3d 637 (Tex. Crim. App. 2006) (factors for Rule 403 balancing)
Beasley v. State, 838 S.W.2d 695 (Tex. App.—Dallas 1992) (preservation rule: unpreserved complaints on certain grounds not reviewable)