Laura Knight v. State
457 S.W.3d 192
| Tex. App. | 2015Background
- Laura Knight was captured on Walgreens surveillance picking up a hydrocodone prescription for Judy Cox five days after Cox's death; Walgreens' records showed a $17.07 express-pay charge to Cox's sister’s account for that refill.
- The foster-home medication system stored residents’ prescriptions in an unlocked cabinet; Knight had access and sometimes administered her mother’s meds.
- Knight left messages and told foster-home staff she had been given the wrong prescription (claimed she went to pick up her son’s medication); she later returned a large vial containing 24 tablets labeled for Judy Cox and demanded a Walgreens letter admitting error.
- Walgreens issued a letter confirming Knight returned 24 tablets of Hydrocodone/APAP (10mg/325mg) that she had allegedly received in error from a vial labeled for Judy Cox (original prescription dispensed was 240 pills).
- Pharmacy witnesses (pharmacist supervisor and store manager) identified the pills as hydrocodone by markings and dispensing records; the supervisor weighed 240 pills of the same lot/type and testified they weighed over 100 grams.
- Knight was convicted of knowingly or intentionally possessing hydrocodone (28–200 grams aggregate) and sentenced to two years; she appealed arguing insufficiency of evidence and erroneous admission of extraneous-offense testimony.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Knight) | Held |
|---|---|---|---|
| Sufficiency of evidence on intent/knowledge | Circumstantial evidence (video, request by name, vial label, no express-pay account, inconsistent statements, admissions) supports inference Knight knowingly/intentionally possessed Cox’s hydrocodone | Walgreens’ letter saying she received the vial "in error" and her statements that she was given her son’s meds negate intent/knowledge | Affirmed: jury could reasonably infer she knowingly/intentionally possessed the drug |
| Sufficiency of evidence that pills were hydrocodone | Pharmacy witnesses identified pills by markings and records; store inventory and photograph of identical pills supported identification | Pills were never lab-tested by law enforcement; appellant argued identification required lab analysis | Affirmed: expert pharmacist testimony and records were legally sufficient to identify the pills as hydrocodone |
| Sufficiency of evidence as to aggregate weight (28–200 g) | Pharmacy records showed 240-pill prescription; pharmacist weighed 240 pills of same manufacturer/type (over 100 g); Knight returned only 24 tablets | Tablets actually possessed by Knight were not seized or weighed by police | Affirmed: reasonable inference that the dispensed amount (240 pills) met statutory weight requirement |
| Admission of extraneous-offense testimony | Testimony about Knight previously requesting a deceased patient’s hydrocodone and prior personal prescriptions was admissible to rebut mistake/absence-of-intent theory opened in Knight’s defensive opening | Testimony was impermissible character-conformity evidence, prejudicial, and the State failed to provide required notice | Affirmed: evidence admissible under Rule 404(b) to show intent/knowledge and rebut defensive opening; lack-of-notice complaint forfeited for failure to request continuance; Rule 403 balance favored admission |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (legal sufficiency standard under Due Process)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for appellate review of sufficiency)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial-evidence sufficiency principles)
- Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1991) (admissibility of extraneous-offense evidence and Rule 404(b) framework)
- Bass v. State, 270 S.W.3d 557 (Tex. Crim. App. 2008) (defensive opening statement can open the door to rebuttal in State’s case-in-chief)