Court of Criminal Appeals of Texas

Paul Allan Humason, Appellant v. the State of Texas, Appellee

March 18, 19871987 Tex. Crim. App. LEXIS 548

Summary

The Court of Criminal Appeals of Texas affirmed the Court of Appeals' reversal, holding that the State failed to prove beyond a reasonable doubt that appellant knowingly possessed cocaine. Applying the Jackson v. Virginia standard, the Court found the evidence did not exclude a reasonable hypothesis that appellant was unaware of the drug, making the conviction untenable. The Court emphasized that mere solitary presence and an unzipped bag are insufficient affirmative links to establish knowing possession. Separate opinions dissent on the sufficiency of the evidence and on procedural defects in the stipulated evidence.