Darrian De'Anthony Davis-Sanders v. State, 06-14-00186-CR

Darrian Davis-Sanders pleaded guilty to delivery of <1 gram of cocaine in a school zone; trial court deferred adjudication and placed him on 10-year community supervision with restitution.
State later alleged he violated supervision by possessing methamphetamine and a firearm; after a hearing the court found the allegations true, adjudicated guilt, and sentenced him to 10 years' imprisonment.
Police Officer Gary Van, acting on informant tips about armed meth sellers at a motel, knocked on a room rented by Brittany Guignard (who had outstanding warrants); Van smelled heavy marijuana and observed marijuana in the room.
During a protective sweep and ensuing interaction, Davis-Sanders pointed to a backpack as his and said his handgun was inside; officers found a loaded handgun and, in plain view beneath it, a bag of crystal-like substance later tested as methamphetamine; further search of the backpack revealed additional meth-related items.
Davis-Sanders appealed, arguing trial counsel was ineffective for failing to file a motion to suppress the evidence from the backpack because the search was allegedly unlawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel rendered ineffective assistance by not moving to suppress evidence from the backpack	Davis-Sanders: counsel was ineffective for failing to challenge the legality of the search that produced meth and a firearm	State: record is silent on counsel's reasons; strategic choices are presumed reasonable; multiple factual/legal bases could justify the search and admission (e.g., no expectation of privacy, arrest of Guignard, plain view, consent/statement by Davis-Sanders)	Court: Affirmed. Appellant failed to meet Strickland first prong; counsel's decision may have been reasonable and the record does not rebut that presumption

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong test for ineffective assistance of counsel)
Johnson v. State, 432 S.W.3d 552 (Tex. App.—Texarkana) (discusses Strickland application on direct appeal)
Goodspeed v. State, 187 S.W.3d 390 (Tex. Crim. App.) (requires ineffective‑assistance claims be firmly founded in the record)
Lopez v. State, 343 S.W.3d 137 (Tex. Crim. App.) (addresses when ineffective assistance may be decided on direct appeal)
Ex parte Moore, 395 S.W.3d 152 (Tex. Crim. App.) (discusses expectation of privacy and entry/search issues)
Menefield v. State, 363 S.W.3d 591 (Tex. Crim. App.) (trial counsel should ordinarily be given opportunity to explain actions)
Mata v. State, 226 S.W.3d 425 (Tex. Crim. App.) (presumption of reasonableness when record is silent on counsel's strategy)
Thompson v. State, 9 S.W.3d 808 (Tex. Crim. App.) (limits on resolving ineffective‑assistance claims on direct appeal)