Hartsfield, Richard Earl, PD-1679-14

On April 11, 2013, Tyler police executed a search warrant at a residence where Richard Earl Hartsfield lived; officers detained Hartsfield outside while they searched the house.
Officers recovered cocaine, marijuana, digital scales, and numerous firearms (including handguns, an AK-47, a TEC-9) from various rooms and a water‑heater closet; some drugs and guns were in different rooms.
Detectives testified weapons are commonly used by drug dealers to protect product and profits and opined the weapons facilitated the drug‑distribution offense; one pistol under a couch was testified to be reachable by Hartsfield in about 15 seconds.
Hartsfield was convicted by a jury of possession with intent to deliver between 4 and 200 grams of cocaine in a drug‑free zone; the jury also found he used or exhibited a deadly weapon (a firearm). He was sentenced to life.
Hartsfield appealed the deadly‑weapon finding as legally insufficient; the Twelfth Court of Appeals affirmed, relying on the number/type of weapons, proximity to contraband, and officer testimony. Several separate firearm‑related indictments against Hartsfield were later dismissed by the State.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for deadly‑weapon finding	Hartsfield: No rational juror could find beyond a reasonable doubt that he used or exhibited a deadly weapon because he was detained outside, had no weapon on him, multiple people had access to the house, firearms were stored and hard to reach, and drugs and guns were in different rooms.	State: The cumulative evidence (large number/type of guns, proximity to drugs, officers' expert testimony) permits an inference that the firearms facilitated the drug offense, supporting the deadly‑weapon finding.	Court affirmed: evidence sufficient to support jury's deadly‑weapon finding.

Jackson v. Virginia, 443 U.S. 307 (legal‑sufficiency standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
Patterson v. State, 769 S.W.2d 938 (possession of a firearm on the sofa supported a deadly‑weapon finding because it facilitated custody/management of contraband)
Plummer v. State, 410 S.W.3d 855 (explaining theories—drug‑fortress and proximity—that permit deadly‑weapon findings where weapons facilitate drug offenses)
Coleman v. State, 145 S.W.3d 659 (weapons found elsewhere in the home can cumulatively support a finding that they facilitated drug possession)
Rollerson v. State, 196 S.W.3d 803 (distinguishing "use" and "exhibit" of a deadly weapon and recognizing that possession facilitating a felony can support a deadly‑weapon finding)