Shirley Jean Johnson v. State, 02-15-00115-CR

Shirley Jean Johnson was arrested after police using a seized drug dealer's phone (Josh Weber) exchanged texts with a number later found on a Samsung phone in Johnson's car; no drugs were actually exchanged at the meeting.
Sergeant Chad Lanier (State's sole witness) photographed a subset of texts from the Samsung phone and testified he and the Samsung number exchanged messages that culminated in an apparent $100 drug order.
Lanier testified, based on his knowledge of Weber’s practices and "street" terminology, that $100 equated to roughly 1.25–1.5 grams of methamphetamine.
None of the admitted text messages explicitly identified methamphetamine or stated a specific quantity; Lanier’s messages attempting to confirm "1.5g for $100" received no reply.
Johnson was indicted for conspiracy to possess more than one gram of methamphetamine, tried by jury, found guilty, and sentenced to a two-year state jail term suspended in favor of community supervision; she appealed claiming legal insufficiency of the evidence to prove an agreement and the drug/amount element.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Johnson)	Held
Whether evidence was legally sufficient to prove an agreement to possess >1 g methamphetamine	Lanier’s testimony plus the exchanged texts show an agreement: the $100 request equaled a 1.25–1.5 g meth order based on Weber’s known practices and street terminology	Texts did not identify the substance or amount and there was no evidence Johnson knew Weber’s pricing or the meaning of "$100" as a meth quantity; inferences about her knowledge are speculative	At trial, the jury convicted Johnson; appellant raises sufficiency on appeal (trial conviction stands pending appellate review)

Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson-sufficiency standard applied in Texas review)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (constitutional standard for sufficiency of evidence)
Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (limits on permissible inferences; cannot rest on mere speculation)
Williams v. State, 646 S.W.2d 221 (Tex. Crim. App. 1983) (conspiracy requires agreement to commit the specific offense)
Brown v. State, 576 S.W.2d 36 (Tex. Cr. App. 1979) (corpus delicti of conspiracy includes proof of agreement)
McCann v. State, 606 S.W.2d 897 (Tex. Crim. App. 1980) (State not required to prove completion of substantive offense to convict for conspiracy)
Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (elements of possession: control and knowledge)