Sean Rodriguez Osborn v. the State of Texas, 13-20-00189-CR

On Nov. 20, 2018 police responded to reports of a disturbance and gunshots at Sean Osborn’s residence; Osborn and his four‑year‑old child were the only persons the officers found in the home.
Officers observed Osborn acting paranoid, erratic, and talking to people not present; he later engaged in a prolonged standoff and used a gun to keep police from entering.
Police recovered two bongs in a bedroom used by Osborn’s child; liquid from one bong tested positive for 60.26 grams of methamphetamine.
Osborn admitted prior personal meth use, admitted burning a washcloth he believed had meth on it, denied the meth found belonged to him, and claimed others lived there and used drugs.
CPS tested the child’s hair and it was positive for methamphetamine; a housemate testified the bong belonged to another resident but also said she had seen Osborn smoke from a similar pipe.
Osborn was convicted of possession of methamphetamine (4–200 g) and received five years; he appealed claiming insufficient evidence to link him to the contraband.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence — were there affirmative links tying Osborn to the meth?	Osborn: evidence insufficient; others lived in the house, presence alone insufficient, no proof he was intoxicated.	State: multiple independent links — meth in plain view and accessible in child’s room, Osborn lived there, paraphernalia present, prior use admission, burned washcloth, observed meth‑like behavior, standoff with gun, child’s positive test.	Affirmed. Court held the combined factors provided affirmative links and a rational juror could find guilt beyond a reasonable doubt.

Whatley v. State, 445 S.W.3d 159 (Tex. Crim. App. 2014) (standard for reviewing sufficiency of the evidence)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (deference to jury on credibility; review in light most favorable to verdict)
Villarreal v. State, 286 S.W.3d 321 (Tex. Crim. App. 2009) (hypothetically correct jury charge guides sufficiency analysis)
Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (elements measured against hypothetically correct charge)
Tate v. State, 500 S.W.3d 410 (Tex. Crim. App. 2016) (affirmative‑link framework for non‑exclusive possession)
Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (factors supporting affirmative links)
Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (non‑exhaustive list of affirmative‑link factors)
McGoldrick v. State, 682 S.W.2d 573 (Tex. Crim. App. 1985) (joint possession doctrine)
Hughitt v. State, 539 S.W.3d 531 (Tex. App.—Eastland 2018) (joint possession suffices; affirmed by higher court)
Barbosa v. State, 537 S.W.3d 640 (Tex. App.—San Antonio 2017) (affirmative links show connection beyond fortuity)