Archie D. Black, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals held that the State failed to prove that the alleged marijuana possession occurred in Smith County, and therefore reversed the conviction and remanded for a new trial. The majority reasoned that venue must be proven by a preponderance of the evidence and that no evidence linked the offense to Smith County, while a dissent argued that judicial notice of Tyler’s location sufficed.