Fountain, Yago Santain, PD-1565-15

Traffic stop of a borrowed 2005 Chevrolet Suburban on I-20; driver Lapatrick Mitchell and passenger Yago Fountain were returning from Dallas to Louisiana.
Trooper obtained consent to search after observing a roll of cellophane and cans of axle grease in a rear compartment; smelled marijuana from beneath the driver-side dashboard and found wrapped bundles (8.59 lbs) in the engine compartment.
Fountain displayed unusual nervousness (unbuckled seatbelt, rapid breathing, trembling hands), gave inconsistent statements about the trip, and said the drugs were not his when confronted.
Jury convicted Fountain of possession of marijuana; sentenced to 10 years and a $10,000 fine.
12th Court of Appeals reversed and rendered acquittal, finding evidence insufficient to prove Fountain exercised care, custody, control, or management of the marijuana despite supporting inferences that he knew of its presence. The State petitioned for discretionary review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence that supports an inference of knowing possession can also reasonably support inference of care, custody, or control	State: the same circumstantial links (proximity, joint travel, nervousness, inconsistent statements, borrowed vehicle, large concealed quantity) reasonably support joint possession/control	Fountain: absence of affirmative links (passenger status, no paraphernalia on person, contraband not in plain view, no flight or incriminating statements) means no control/possession	Court of Appeals: knowledge proven but insufficient evidence of care/custody/control; reversed and acquitted

Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (lists nonexclusive "links" for circumstantial proof of possession and explains presence/proximity + links may suffice)
Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (elements of possession: control/management/care and knowledge; affirmative-links rule)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review — whether any rational trier of fact could find guilt beyond reasonable doubt)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (deference to factfinder on credibility and conflicts; limits appellate reweighing)
Blackman v. State, 350 S.W.3d 588 (Tex. Crim. App. 2011) (affirmative independent facts can link passenger to hidden contraband where circumstantial facts have strong logical force)
Hernandez v. State, 538 S.W.2d 127 (Tex. Crim. App. 1976) (absence of affirmative links does not become affirmative evidence of innocence)