Bobby Glenn Canida v. State, 387 S.W.3d 668

Appellant Bobby Glenn Canida was convicted by a jury of manufacturing methamphetamine (>1 gram but <4 grams).
Canida was sentenced to eighty years’ imprisonment after true-findings on a State’s enhancement paragraph.
The sole point of error is legal sufficiency of the evidence supporting the manufacture conviction.
The State must prove manufacture by evidence of any stage of the process or equivalent preparation under the statute.
Evidence showed items and testimony suggesting a meth lab and potential manufacturing, plus Canida’s admissions.
Court held the evidence insufficient to prove more than one gram was manufactured at the time of arrest, reversing and acquitting.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence legally sufficient to prove manufacture of methamphetamine?	State contends evidence showed ongoing manufacture.	Canida argues insufficient proof of quantity; not enough to show >1 gram.	Yes; insufficient evidence of quantity; acquittal warranted.

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard of legal sufficiency under Jackson v. Virginia)
Jackson v. Virginia, 443 U.S. 307 (1979) (due-process sufficiency framework)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (deference to jury’s fact-finding in sufficiency review)
Fronatt v. State, 630 S.W.2d 703 (Tex. App.—Houston [1st Dist.] 1981) (definitions of manufacturing include preparation/processing)
Green v. State, 930 S.W.2d 655 (Tex. App.—Fort Worth 1996) (presence at scene as circumstantial support)
Goff v. State, 777 S.W.2d 418 (Tex. Crim. App. 1989) (need to prove aggregate weight including dilutants)
Brumit v. State, 42 S.W.3d 201 (Tex. App.—Fort Worth 2001) (evidence insufficient to prove future manufacturing capacity from leftovers)
Hardie v. State, 79 S.W.3d 625 (Tex. App.—Waco 2002) (burden to prove actual quantity manufactured)