James Lee Knight v. State, 03-16-00093-CR

Appellant James Lee Knight was convicted by a jury of possession with intent to deliver methamphetamine (4g–200g); sentence: 10 years’ imprisonment, probated for 10 years.
Officers arranged a controlled buy; a cooperating individual sought ~1 ounce of methamphetamine and was to buy through Virginia Lara.
In a parking lot, a truck arrived; Harris (driver), Knight (front passenger), and Lara (rear passenger) were detained after Lara entered the truck.
Officers found a cigarette pack in the driver’s seat containing ~28 grams of methamphetamine and a glass pipe in the center console.
Knight wore gloves with metal knuckles, carried $1,345 in cash folded in increments consistent with drug sales, and remained in the vehicle providing what officers described as “security” or an “enforcer” role.
Knight appealed, arguing the evidence was insufficient to show (1) he knew the quantity of the drugs and (2) he was criminally responsible under the law of parties for Harris’s possession with intent to deliver.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Knight was criminally responsible under the law of parties	State: Knight acted as security/enforcer, aiding Harris’s delivery, so he is criminally responsible	Knight: No evidence he assisted or had common design; mere presence insufficient	Court: Evidence sufficient—knuckles, cash folded for sales, pipe, and remaining in vehicle support inference he aided/encouraged the sale
Sufficiency of evidence that Knight knew the quantity (4g–200g)	State: Even if Harris possessed the drugs, Knight is responsible under parties for Harris’s possession and intent	Knight: No proof he knew amount, so cannot be guilty of that statutory quantity range	Court: Did not need independent proof because evidence showed Harris committed the offense and Knight was criminally responsible for Harris’s conduct; conviction upheld

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for reviewing sufficiency of the evidence)
Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (consider all evidence admitted and view in light most favorable to verdict)
Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (courts may consider events before, during, and after to infer common design)
Gross v. State, 380 S.W.3d 181 (Tex. Crim. App. 2012) (requirement of understanding and common design under law of parties)
Cordova v. State, 698 S.W.2d 107 (Tex. Crim. App. 1985) (reliance on cumulative incriminating facts to show party liability)
Chambers v. State, 805 S.W.2d 459 (Tex. Crim. App. 1991) (jury is sole judge of witness credibility)