Paul Andrew Thornhill v. the State of Texas, 09-19-00413-CR

Thornhill was indicted for possession of methamphetamine with intent to deliver (first‑degree felony) and alleged a prior felony enhancement; trial court granted motion in limine excluding extraneous‑offense evidence.
Police responded after a truck was reported stolen and located at a house; Detective Hernandez encountered Thornhill exiting the house holding a large knife and detained him.
Hernandez observed in plain view two spoons and scales with a crystal‑like substance on a coffee table, asked for consent to search the residence (initial consent for locating a driver, then Thornhill denied consent to search whole residence and said the house belonged to his deceased brother), then obtained a warrant.
Search uncovered multiple baggies and approximately 15 grams of methamphetamine in a bedroom (amount consistent with distribution) and additional smaller amounts; Thornhill had over $800 cash on him; forensic testing confirmed methamphetamine.
Jury convicted Thornhill of possession with intent to deliver; he pleaded true to the enhancement and received 15 years’ confinement; Thornhill appealed alleging (1) legal insufficiency (lack of affirmative links) and (2) denial of motion for mistrial based on limine violation.

Issue	Thornhill's Argument	State's Argument	Held
Sufficiency of evidence (affirmative links)	Evidence failed to show Thornhill knowingly possessed the bedroom meth because he did not own the house and mere presence is insufficient	Multiple affirmative links (exiting house when officers arrived, plain‑view paraphernalia, proximity to contraband, container with multiple baggies, amount indicative of distribution, $800 on person, consent/interaction with officer) support possession with intent to deliver	Affirmed. Viewing the circumstantial evidence and reasonable inferences in State's favor, a rational juror could find guilt beyond a reasonable doubt.
Motion for mistrial for alleged limine violation	Trial court abused discretion by denying mistrial after State elicited/introduced extraneous‑offense references	Any error was cured: one complained instance was not preserved; the other was a nonresponsive remark to which the court sustained an objection, instructed jury to disregard, and limited further testimony	Affirmed. Error not preserved as to one remark; the court’s prompt instruction to disregard cured the other and denial of mistrial was within the zone of reasonable disagreement.

Brooks v. State, 323 S.W.3d 893 (standard of legal‑sufficiency review in Texas)
Jackson v. Virginia, 443 U.S. 307 (federal standard for sufficiency review)
Evans v. State, 202 S.W.3d 158 (affirmative‑links principle protects innocent bystanders)
Roberts v. State, 321 S.W.3d 545 (enumeration of factors that may link defendant to contraband)
Hooper v. State, 214 S.W.3d 9 (view circumstantial and direct evidence equally; reasonable‑inference analysis)
Ovalle v. State, 13 S.W.3d 774 (prompt jury instruction to disregard generally cures inadvertent extraneous‑offense references)
Coble v. State, 330 S.W.3d 253 (denial of mistrial reviewed for abuse of discretion; within zone of reasonable disagreement)