Tate, Dallas Carl, PD-0730-15

Police stopped a Pontiac Grand Prix driven by Dallas Carl Tate to arrest him on outstanding warrants; two female passengers and a dog were in the car.
Tate stated he owned the car; after he was arrested and removed, officers impounded and inventoried the vehicle pursuant to policy.
During the inventory, officers found a syringe containing .24 grams of methamphetamine in an open compartment under the radio/climate controls, in plain view and within reach of the driver and front passenger.
Tate admitted a prior drug-possession conviction, knew the passengers and had dated one; he denied placing or knowing about the syringe and suggested a passenger might have put it there.
The Fort Worth Court of Appeals reversed, finding the only link between Tate and the syringe was his driver/owner status and convenient access; the State argues that court misapplied sufficiency review and ignored other links.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Tate)	Held (Court of Appeals)
Whether evidence was legally sufficient to prove possession of a controlled substance	The syringe was in plain view in Tate’s car within his reach; combined with his drug history and association with known drug-offenders, a rational jury could infer knowledge and control	Tate argued mere proximity and ownership of the car—without direct proof linking him to the syringe—does not establish possession; a passenger could have placed it	The court of appeals held the evidence insufficient, finding only driver/owner status and convenient access as links
Whether the court of appeals applied correct sufficiency review standards	The State contends the court ignored evidence, reweighed credibility, and improperly substituted its judgment for the jury’s	Tate contends the appellate court properly required more direct links and noted gaps (no fingerprints, syringe not observed prior to his exit)	The appellate ruling favored Tate; the State asks the CCA to reverse that insufficiency finding

Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App.) (describing required elements for possession and the need for links beyond mere proximity)
Evans v. State, 202 S.W.3d 158 (Tex. Crim. App.) (explaining sufficiency review and deference to jury in weighing evidence and alternative inferences)
Geesa v. State, 820 S.W.2d 154 (Tex. Crim. App.) (confirming jury’s exclusive role in factfindings and credibility assessments)
Tate v. State, 463 S.W.3d 272 (Tex. App.—Fort Worth) (appellate decision reversing conviction for insufficiency of evidence)
Murray v. State, 457 S.W.3d 446 (Tex. Crim. App.) (cautioning against appellate courts making credibility determinations or reweighing evidence)
Abercrombie v. State, 528 S.W.2d 578 (Tex. Crim. App.) (example where absence at search did not preclude possession conviction when other links supported guilt)