Matthew Jarrett Lee v. State, 03-15-00112-CR

On Dec. 8, 2013, deputies stopped a vehicle with four occupants (driver, front passenger female, rear-seat adult male — Lee — and an infant). A small bag of marijuana (≤2 oz.) was found on the rear floorboard under/near the infant’s car seat.
Deputies obtained consent to search; marijuana was in plain view on the back floorboard, about a foot from where Lee had been seated and within his arm’s reach.
Deputies testified Lee exhibited repeated statements (“I don’t want no trouble,” “I’m just along for the ride”), shaking, bloodshot eyes, and an immediate desire to exit the vehicle — behavior they characterized as unusually nervous compared to the other occupants.
Officers saw no movement by the other adults indicating they placed the marijuana in the back while the vehicle was moving and testified it would have been difficult for them to do so.
Lee was convicted by a jury of misdemeanor possession of marijuana; court sentenced him to 90 days (suspended) and 12 months’ community supervision. Lee appealed sole issue: sufficiency of the evidence to prove actual possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to prove actual possession of marijuana found in vehicle	State: combined circumstantial links (presence, plain view, proximity, easy access, nervous behavior, attempts to exit) establish actual control and knowledge	Lee: links are individually weak; absence of odor, paraphernalia, or direct proof makes evidence insufficient — presence alone cannot prove possession	Affirmed: cumulative and combined circumstantial evidence was sufficient for a rational jury to find possession beyond a reasonable doubt

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (defer to jury credibility and consider combined evidence)
Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (affirmative-links framework for proving possession via circumstantial evidence)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence can be as probative as direct evidence)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (jury deference on credibility and viewing evidence in light most favorable to verdict)