Clifton James Grimes v. the State of Texas, 08-20-00111-CR

At ~3:00 a.m. on Jan. 15, 2019, Sgt. Sawyer stopped Clifton Grimes for a faulty taillight and expired registration near a house suspected of narcotics activity; Grimes immediately exited his truck and appeared agitated.
During a defensive pat-down, the officer felt a bundle in Grimes’s right jacket pocket; when asked what it was, Grimes said, “It’s speed is what it is,” and a plastic baggie of white crystals was recovered.
Officer recovered a broken pipe and syringe from Grimes’s left pocket; jail intake later produced a second plastic baggie with a white powder hidden in a cigarette pack.
The State admitted a certificate of analysis, chain‑of‑custody affidavit, and attached lab report (without objection) showing the seized substance weighed 9.38 grams and tested positive for methamphetamine.
Grimes testified Barker’s wife had borrowed his jacket and could have placed the contraband there; he also denied knowledge of the cigarette pack baggie.
The jury convicted Grimes of possession of methamphetamine (4 grams or more but less than 200 grams), found prior felony enhancements true, and assessed a 40‑year sentence; Grimes appealed asserting (1) denial of Faretta self‑representation rights and (2) legal insufficiency of the evidence regarding identity/weight of the drug.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Grimes)	Held
Denial of self‑representation	Trial court properly exercised discretion; Grimes exhibited paranoia, delusional/bizarre statements, disruptive behavior, and lacked the ability to conduct trial — court could require counsel under Edwards/Chadwick	Sixth Amendment violated; counsel was forced on him and he expressly sought to represent himself	Affirmed — trial court did not abuse discretion; record showed bizarre/paranoid conduct and the court reasonably found him incompetent to proceed pro se
Legal sufficiency (identity/weight of substance)	Introduced timely certificate of analysis, chain‑of‑custody affidavit, and attached lab report showing 9.38g methamphetamine; no timely objection so State could rely on Articles 38.41/38.42; jury also had Grimes’s admissions and paraphernalia	Argued State failed to produce expert testimony and lab tech; certificate in clerk’s record allegedly lacked the lab report, so identity/weight not proven beyond reasonable doubt	Affirmed — evidence (lab report admitted at trial, statements, paraphernalia, and possession in jacket/cigarettes) was legally sufficient to prove 9.38g methamphetamine and Grimes’s knowing possession

Faretta v. California, 422 U.S. 806 (right to self‑representation)
Indiana v. Edwards, 554 U.S. 164 (states may insist on counsel for severely mentally ill defendants who are competent to stand trial)
Gideon v. Wainwright, 372 U.S. 335 (right to counsel and appointment if indigent)
Jackson v. Virginia, 443 U.S. 307 (standard for legal sufficiency review)
Brooks v. State, 323 S.W.3d 893 (Texas applies Jackson legal‑sufficiency standard)
Chadwick v. State, 309 S.W.3d 558 (trial judge best positioned to assess competency to self‑represent)
Blackman v. State, 350 S.W.3d 588 (elements of possession: care, custody, control, and knowledge)
Malik v. State, 953 S.W.2d 234 (hypothetically correct jury charge framing)
Jenkins v. State, 870 S.W.2d 626 (contraband found in pocket supports knowing possession)
Sneed v. State, 875 S.W.2d 792 (possession of other contraband/paraphernalia supports knowing possession)