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

Appellant Matthew Jarrett Lee, a rear-seat passenger, was charged with Class B misdemeanor possession of marijuana (under 2 ounces) after officers found a small bag of marijuana on the rear passenger floorboard beneath an infant carrier.
The vehicle had four occupants: Driver (owner), front-seat Passenger, an infant in a carrier, and Lee sitting on the rear driver-side.
Officers removed Lee from the car, placed him on the curb, and later searched the vehicle after Driver consented; the marijuana was found roughly a foot from where Lee had been sitting about ten minutes earlier.
No one observed Lee holding, discarding, or attempting to hide the marijuana; no paraphernalia, large cash, or odor of marijuana was reported.
Prosecution relied principally on three links: (1) Lee’s proximity to the contraband, (2) his allegedly bloodshot eyes, and (3) his nervous behavior. The jury convicted; sentence was 90 days probated and a fine.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Lee)	Held (as argued by appellant brief)
Sufficiency of evidence to prove knowing/intentional possession	Proximity to contraband plus bloodshot eyes and nervousness link Lee to possession and knowledge	Proximity alone is insufficient; bloodshot eyes and nervousness are equivocal and do not establish knowledge or control	Appellant argues evidence was legally insufficient and requests reversal and acquittal

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (Due Process requires proof beyond a reasonable doubt; sufficiency review standard)
Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (enumerates non‑exclusive factors linking defendant to contraband; proximity alone insufficient)
Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (requires independent linking evidence when defendant lacks exclusive control)
Allen v. State, 249 S.W.3d 680 (Tex. App.—Austin 2008) (application of Evans factors where proximity and some incriminating evidence failed to prove knowing possession)
Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (standards for reviewing circumstantial and direct evidence combined)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standards for reviewing fact‑finder’s inferences under sufficiency review)
Glass v. State, 681 S.W.2d 599 (Tex. Crim. App. 1984) (nervousness alone is equivocal and common in encounters with police)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (trial court need not accept testimony contradicted by indisputable video evidence)