James Cunningham v. State, 06-15-00129-CR

Cunningham was convicted of unlawful possession of a firearm, a third-degree felony, with punishment enhanced by two prior convictions.
Evidence showed a June 23, 2014 offense involving a handgun and a car chase on Gato Street in Bryan, Texas.
Witnesses testified Cunningham was present in the car and may have possessed or fired a handgun; some conflicts existed about his exact seat and actions.
The State introduced testimony from Edwards through Detective Fry, including hearsay statements, because Edwards did not testify.
Cunningham stipulated to a prior felony conviction for possession of a firearm by a felon; the jury found a deadly weapon finding, but punishment was set by the court at 20 years.
Anders counsel filed a motion to withdraw, asserting no meritorious issues; appellate issues were presented but ultimately found nonmeritorious.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Cunningham: evidence insufficient to prove firearm possession.	State: sufficient evidence showing possession on date alleged.	Evidence legally sufficient to prove possession beyond a reasonable doubt.
Admission of extraneous-offense evidence	State could introduce extraneous-offense evidence to show motive/intent.	Admission violated specificity of indictment and risked prejudice.	Non-constitutional error; not reversible given lack of substantial prejudice.
Hearsay statements of codefendant not cross-examined	Edwards' statements supported elements of the offense.	Hearsay and confrontation concerns should invalidate those statements.	Error preservation failed; issues waived; no reversible error identified.
Juror misconduct and new trial	Juror knew witnesses; could warrant new trial.	Record undeveloped; remedy is motion for new trial or habeas corpus.	No meritorious basis; record insufficient to grant new trial.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard: rational juror could convict beyond reasonable doubt)
Ngo v. State, 175 S.W.3d 738 (Tex. Crim. App. 2005) (unanimity on the same criminal act required, not necessarily the same method)
Moff v. State, 131 S.W.3d 485 (Tex. Crim. App. 2004) (considering allegedly inadmissible evidence in sufficiency review)
Laster v. State, 275 S.W.3d 512 (Tex. Crim. App. 2009) (circumstantial evidence in sufficiency review; reasonable inferences allowed)
Matchett v. State, 941 S.W.2d 922 (Tex. Crim. App. 1996) (conflicting testimony does not render evidence insufficient)
Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (credibility determinations lie with the jury)
Williamson v. State, 244 S.W.2d 202 (Tex. Crim. App. 1951) (united elements and reasonable inferences in sufficiency analysis)
Huffman v. State, 267 S.W.3d 902 (Tex. Crim. App. 2008) (framework for evaluating trial errors and harm)
King v. State, 953 S.W.2d 266 (Tex. Crim. App. 1997) (relevance and prejudice balancing; standard for improper extraneous evidence)
Uranga v. State, 247 S.W.3d 375 (Tex. App.—Texarkana 2008) (voir dire and juror knowledge as due process concerns)
Salazar v. State, 562 S.W.2d 480 (Tex. Crim. App. 1978) (juror misconduct and procedural remedies)