Julian Leonard Haynes v. State
12-17-00007-CR
| Tex. App. | Oct 31, 2017Background
- On Aug. 25, 2012, Polk County deputies responded to a tip about narcotics at a trailer; Julian Haynes (appellant) answered the door; his brother Clyde and a child were present.
- Haynes consented to a pat search; Clyde told officers he used marijuana and said a search would find some; Clyde consented to a living-room search but Haynes did not consent to a bedroom search.
- Deputies obtained a warrant and searched the remainder of the home. Multiple bags of marijuana were found in Haynes’s bedroom: a bag in shorts on the bed (with Clyde’s license in the pocket), a large bag in a dresser drawer, and five bags in a shoebox on an ironing board.
- Drug paraphernalia (scale, sandwich bags, cloth bags) were found in the bedroom; Haynes’s work badge was under the ironing board.
- Haynes was indicted for possession of marijuana (amount: >4 oz but ≤5 lb), tried by jury, found guilty, sentenced to two years (suspended) with two years’ community supervision, and appealed claiming insufficient evidence of possession.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Haynes) | Held |
|---|---|---|---|
| Sufficiency of evidence to prove Haynes knowingly possessed the marijuana | The State: Haynes lived in the trailer; drugs were in his bedroom, within his proximity and access; paraphernalia and scales linked him to possession; he was present during the search. | Haynes: Evidence showed only proximity and presence; connections are insufficient to prove care, custody, control, or management—his brother’s involvement and a bag with Clyde’s license undermine attribution. | Affirmed: Jury rationally found beyond a reasonable doubt that Haynes exercised care, custody, control, or management and knowingly possessed the marijuana. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of evidence)
- Brooks v. State, 323 S.W.3d 893 (deference to jury in credibility and weighing evidence)
- Hooper v. State, 214 S.W.3d 9 (circumstantial evidence can be as probative as direct evidence)
- Poindexter v. State, 153 S.W.3d 402 (elements required to prove unlawful possession)
- Evans v. State, 202 S.W.3d 158 (presence/proximity plus other factors can establish possession)
- Olivarez v. State, 171 S.W.3d 283 (nonexclusive list of factors connecting defendant to contraband)