Ronnie Dean Davis v. State
05-14-00378-CR
| Tex. App. | Apr 2, 2015Background
- Police performed a consensual knock-and-talk at 6045 Wofford Dr. after a citizen complaint; Monica Day answered and initially denied homeowner status; Ronnie Davis later came to the door and refused consent to search.
- Officers detained Laci Martinez leaving the back of the house; she told officers there were drugs inside, and police obtained a search warrant.
- In the bedroom with a large Harley‑Davidson headboard (the “Bedroom”), officers found drug paraphernalia, packaging materials, scales, syringes, a BB gun, handcuffs, methamphetamine residue, and a 2.75‑gram shard of methamphetamine; mail, clothing, a wooden plaque reading “Ronnie,” and skull imagery linked the room to Davis.
- Witnesses and recorded jail calls produced conflicting ownership evidence: Martinez and jail calls tied the Bedroom to Davis, while defense witnesses said the room belonged to a cousin/roommate and Davis denied it was his.
- Davis was convicted by a jury of possession with intent to deliver methamphetamine; he appealed raising sufficiency of evidence, a claim the sentence was void due to indictment amendment issues, and two jury‑charge errors (law of parties instruction and failure to give a "benefit of the doubt" lesser‑included instruction).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Davis) | Held |
|---|---|---|---|
| Sufficiency of evidence to prove Davis was primary actor or party | Evidence (drugs in plain view, baggies, scales, paraphernalia in Bedroom, mail/Ronnie plaque, tattoos/door similarity, testimony placing Davis in the Bedroom) sufficiently links Davis to contraband | Bedroom not Davis’s; no direct link showing he possessed the meth; mere presence insufficient | Affirmed: circumstantial links permitted jury to conclude Davis possessed drugs beyond reasonable doubt (Jackson standard) |
| Jury charge — law of parties instruction | Inclusion justified as applicable alternative | Instruction improper because no evidence Davis was a party to others’ acts | Overruled: even if error, evidence supported guilt as primary actor so any error harmless (Cathey) |
| Jury charge — failure to instruct jury to resolve reasonable doubt in favor of lesser‑included offense | Charge already guided jury to consider lesser offense if doubt existed | Trial court erred by not sua sponte giving express "benefit of the doubt" instruction | Overruled: charge, read as whole, left no uncertainty; omission harmless (Shelby/Villarreal analogs) |
| Indictment/amendment of enhancement paragraphs; sentence void | State failed to properly amend indictment/enhancement so sentence void | Trial court granted motion to amend; defense had opportunity and waived objections; Davis pleaded true to enhancements | Overruled: Davis waived objections by not timely objecting and pleading true; enhancements need not be physically repleaded in indictment to provide notice |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes single‑standard sufficiency review under due process)
- Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (additional facts required to link nonexclusive possessor to contraband)
- Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (nonexclusive list of factors to link accused to contraband)
- Cathey v. State, 992 S.W.2d 460 (Tex. Crim. App. 1999) (charging on parties harmless where evidence supports guilt as primary actor)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence can be sufficient to prove guilt)
- Winfrey v. State, 393 S.W.3d 763 (Tex. Crim. App. 2013) (deference to jury credibility and weight determinations)