Jamie Lee Jaramiello v. State, 12-17-00064-CR

Police temporarily stopped Jamie Lee Jaramiello; dispatch identified her as a suspect in theft of two cell phones and Sergeant Kerr confirmed one iPhone in her possession was stolen.
Jaramiello was arrested and Sergeant Kerr searched her handbag and found a glass marijuana pipe, Seroquel, Xanax, two unidentified pink pills, one used syringe, two unused syringes, and her wallet.
Inside the wallet was a plastic bag containing 0.3 grams of a substance later confirmed by lab analysis to be methamphetamine.
During the search (before the meth was found) Jaramiello told her husband to take responsibility for his belongings; afterward she denied ownership and made inconsistent statements (claimed she didn’t know where to buy drugs, later offered a dealer’s name and to buy meth for police).
A jury convicted Jaramiello of possession of less than one gram of a Penalty Group 1 controlled substance; the trial court sentenced her to 21 months in TDCJ—State Jail Division.
Jaramiello appealed, arguing (1) evidence was insufficient to prove knowing possession and (2) the 21‑month sentence was cruel and unusual and grossly disproportionate.

Issue	Jaramiello's Argument	State's Argument	Held
Sufficiency of the evidence to prove knowing possession of methamphetamine	The evidence did not establish she knowingly possessed the meth; the connection was only fortuitous	Physical possession (meth in her wallet in her purse), drug paraphernalia in purse, and her consciousness‑of‑guilt statements support knowing possession	Affirmed — evidence (direct and circumstantial) was sufficient for a rational jury to find knowing possession
Cruel, unusual, or excessive punishment (Eighth Amendment)	21‑month sentence is disproportionate to the offense given the small amount of meth	Sentence is within statutory range; not grossly disproportionate especially given prior record and legislative sentencing scheme	Affirmed — claim not preserved for review; even if considered, sentence within statutory range and not grossly disproportionate

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (deference to jury fact‑finding in sufficiency review)
Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (all evidence includes properly and improperly admitted evidence)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence and reasonable inferences)
Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (elements of unlawful possession: control and knowledge)
Victor v. State, 995 S.W.2d 216 (Tex. App.—Houston [14th Dist.] 1999) (visible/measurable amount supports knowledge)
Shults v. State, 575 S.W.2d 29 (Tex. Crim. App. 1979) (small unmeasurable quantities require additional proof of knowledge)
Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (factors linking defendant to drugs may be considered cumulatively)
McGruder v. Puckett, 954 F.2d 313 (5th Cir. 1992) (gross disproportionality threshold for Eighth Amendment review)
Solem v. Helm, 463 U.S. 277 (1983) (framework for proportionality analysis)
Ex parte Chavez, 213 S.W.3d 320 (Tex. Crim. App. 2006) (sentences within statutory range generally unassailable)
Rummel v. Estelle, 445 U.S. 263 (1980) (upholding severe sentence under gross‑disproportionality analysis)