Stephanie Maie Heintzlemann v. State
03-15-00258-CR
Tex. App.Nov 20, 2015Background
- Appellant Stephanie Maie Heintzlemann was convicted by a jury in Burnet County for possession with intent to deliver methamphetamine (1–4 grams).
- Punishment imposed was 9 years’ confinement; appeal filed from verdict and sentence.
- Police stopped a vehicle in Granite Shoals; meth residue and other drug paraphernalia were found in bags in the car.
- Appellant was a passenger; contraband was found in bags associated with the vehicle.
- The State relies on the Link Doctrine to show affirmative connections between Heintzlemann and the contraband; Heintzlemann challenges lack of exclusive possession and insufficient affirmative links.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there sufficient evidence tying Heintzlemann to the contraband under the Link Doctrine? | Heintzlemann lacked exclusive possession and any affirmative links. | State asserts presence and proximity create inferential linkage to the drugs. | No sufficient affirmative links; conviction reversed/acquittal warranted. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence)
- Brooks v. State, 323 S.W.3d 893 (Tex.Crim.App.2010) (standard for sufficiency and credibility on appeal)
- Olivarez v. State, 171 S.W.3d 283 (Tex.App.-Houston [14th Dist.] 2005) (affirmative-links framework for non-exclusive possession cases)
- Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App. 2005) (affirmative links to contraband and possession evidence)
- Evans v. State, 202 S.W.3d 158 (Tex. Crim. App. 2006) (list of affirmative-link factors and evaluative framework)