Jackson, Jason B.

CourtTexas Supreme Court
DecidedJuly 10, 2015
DocketPD-0557-15
StatusPublished

This text of Jackson, Jason B. (Jackson, Jason B.) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jackson, Jason B., (Tex. 2015).

Opinion

5S7-/5 IN THE ORIGINAL TEXAS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

FILED IN COURT OF CRIMINAL APPEALS

JASON JACKSON JUL 10 2015 VS. Abel Acosta, Clerk STATE OF TEXAS

PETITION FOR DISCRETIONARY REVIEW

On Discretionary Review From The COURT OF APPEALS FOURTEENTH DISTRICT OF TEXAS , HOUSTON, TEXAS No. 14-14-00150-CR

On Appeal From The 176th District Court Harris County, Texas Trial Cause 1333636

JASON JACKSON, PRO-SE TDCJ-CID# 1940366 COFFIELD UNIT 2661 PM 2054 TENNESSEE COLONY,TX 75884

ItiCElVED IN ffifflOFCRIMINAL APPEALS EVIDENTIARY HEARING REQUESTED JUL 10 2011 TABLE OF CONTENTS

Page

INDEX OF AUTHORITY ... ... ... ii

STATEMENT REGARDING ORAL ARGUMENT ... iii

STATEMENT OF THE CASE ... ••• • ••*• ••• iii

STATEMENT OF PROCEDURAL HISTORY ... iii

QUESTION[S] PRESENTED FOR REVIEW ..... ... 1

WHETHER THE FOURTEENTH COURT OF APPEALS ERRED IN FINDING THE EVIDENCE SUFFICIENT TO PROVE BEYOND A REASONABLE DOUBT THAT PETITIONER KNOWINGLY AND INTENTIONALLY POSSESSED A CONTROLLED SUBSTANCE WITH INTENT TO DELIVER? 1

WHETHER THE JUSTICES OF THE FOURTEENTH COURT OF APPEALS HAVE DISAGREED ON A MATERIAL QUESTION OF LAW NECESSARY TO THIS COURT'S DECISION? 1

ARGUMENT ..... 2

PRAYER FOR RELIEF.... ... 11

APPENDIX ... [ OPINION: -COURT.OF.APPEALS.].. 12

-l- INDEX OF AUTHORITIES Cases Page Allen v. State,249 S.W.3d'68(Tex.App.-Austin,2008,no pet.) 7,8,9 Avila v. State,15 S.W.3d 568(Tex.App.-Houston[14th Dist.] 2000 no pet.) 6 Brooks v. State,323 S.W.3d 893(Tex.Crim.App.2010) 3 Brown v. STATE, (911 S.W.2d 744( Tex .Crim. App. 1995')' 6 Evans v. State 202 S.W.3d 158(Tex.Crim.App.2006) 5,6,9 Fisher v. State,887 S.W.2d 49(Tex.Crim.App.1994)(Op.on rehrg) 4 Flores v. State,100113 TXCA 14,14-12-00623-CR,Oct.1,2013) 9 Gear v. State,340 S.W.3d 743(Tex.Crim.App.2011) 4 Humason v. State,699 S.W.2d 922(Tex.App.-Houston!1st Dist.] 1985,aff'd, 728 S.W.2d 363(Tex.Crim.App.1987) 6,10 Isassi v. State,330 S.W.3d 633(Tex.Crim.App.2010) 4 Jackson v. Virginia,443 U.S. 307,99 S.Ct. 2781,61 L.Ed.2d 560(1979) 4 Medina v. State,2011 WL 6013094(Tex.App.-Houston[14th Dist] 2011,pet.ref'd.) 9 Oaks v. State,642 S.W.2d 174(Tex.Crim.App.1982) 8 Olivarez v. State,171 S.W.3d 283(Tex.App.-Houston[14th Dist] 2005,no pet.) 6 Poindexter v. State,153 S.W.3d 402(Tex.Crim.App.2005) 4 U.S. v. Phillips, 496 F.2d 1395(5th Cir.1974) 7 U.S. v. Rojas Alvarez, 451 F.3d 320(5th Cir.2006) 7

STATUTES

TEX.HEALTH AND SAFETY CODE:

Art. 481.112 3 TEX.PENAL CODE

Art. 6.01 ~ 3 Art. 46.04 3 RULES

TEX.R.APP.P.:

RULE 68.4(a) i RULE 68.4(b) ii RULE 68.4(c), (d), (e) iii RULE 68.4(f) 1 RULE 66.3(e) 1

-li- STATEMENT REGARDING ORAL ARGUMENT T.R.A.P. 68.4(c)

Oral argument is requested as it will aid the Court in deciding

this unique set of facts herein.

STATEMENT OF THE CASE T.R.A.P. 68.4(d)

Petitioner was charged by indictment in cause No. 1333636 with

the offense of possession of a controlled substance, namely

cocaine weighing between one and four grams, with intent to

deliver. The offense was allegedly committed on January 18,2012.

(Clerk's Record,10). The indictment included one enhancement

alleging a prior felony conviction. (Id.) Petitioner filed a

motion to suppress statements made in the course of custodial

interrogation. (Id.,63). The motion was granted.(Reporter's Record

IV,7-8,39).

Petitioner entered a plea of not guilty and a jury was empanelled.

(Id.,9). The jury returned a verdict of guilty.(Id.,99).

On January 29,2014,after a hearing on punishment,the Court

found the enhancement, paragraph to be true and sentenced him

to a term of 5 years in the Texas Department of Criminal Justice

Institutions Division. (Clerk's Record,88)

STATEMENT OF PROCEDURAL HISTORY T.R.A.P. 68.4(e)

Petitioner was convicted in cause 1333636 with possession

of a controlled substance (cocaine) between one and four grams, .

with intent to deliver. On January 29,2014 after a hearing on

punishment he was sentenced to 5 years in prison. He timely appealed. No motion for rehearing was filed. The Fourteenth Court of APPEALS AFFIRMED ON April 16,2015. An extension of time to file

PDR was granted until July |7th,2015 making this timely submitted.

-in- QUESTION PRESENTED FOR REVIEW T.R.A.P. 68.4(f) WHETHER THE FOURTEENTH COURT OF APPEALS ERRED IN FINDING THE EVIDENCE SUFFICIENT TO PROVE BEYOND A REASONABLE DOUBT THAT PETITIONER KNOWINGLY AND INTENTIONALLY POSSESSED A CONTROLLED SUBSTANCE WITH INTENT TO DELIVER?

T.R.A.P. 66.3(e) WHETHER THE JUSTICES OF THE FOURTEENTH COURT OF APPEALS HAVE DISAGREED ON A MATERIAL QUESTION OF LAW NECESSARY TO THIS COURT'S DECISION?

Statement Of Facts

At 3:54 a.m. on January 18,2012 Sheriff's deputy Herlong was

dispatched to a motel in Houston,Texas to meet a caseworker from Children's Protective Services(CPS).( RR,IV,10-12). The

CPS caseworker Marcil Patrick had been called at 3:30 a.m. to

investigate a tip that drugs were being sold from a motel room where young children were present.(Id.,64,69) Herlong and Patrick

knocked on the door of the motel room and asked permission to

enter. (Id., 15) Looking into the room,Herlong saw an adult male

an adult female,and two very young children.(Id.,16).According

to Herlong the woman gave oral consent to enter.(Id.,23-24) The woman(Shelly Fisher) said,"Let us put some clothes on first," but left the door open.(Id.,32). The man( Jackson) appeared to be walking away from a coatrack beside the sink in an area outside the bathroom. Herlong said the coat seemed to be moving as if Jackson had just handled it.(ID.,17). using a flashlight, Herlong was able to see a scale by the sink. For safety he ordered petitioner to approach him.(ID.,18) Herlong detained petitioner and turned on the light in the room. At that point he observed powder residue on the scale.(Id.,19). In a pocket of a coat on the coatrack Herlong found a pill container with plastic baggies holding more powder.(Id.,20). Herlong could not say if the coat was a man's or a woman's coat; he admitted -1- that the drugs found in the pocket could possibly have belonged

to Shelly„Fisher.(Id.,25-27). He did not search Fisher's purse

eventhough the original call slip read "investigate Shelly Fisher

who is selling drugs with her boyfriend and has a 2-month old

and a 2-year old in the room".(Id.,34-35).

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Related

United States v. Rojas Alvarez
451 F.3d 320 (Fifth Circuit, 2006)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Poindexter v. State
153 S.W.3d 402 (Court of Criminal Appeals of Texas, 2005)
Allen v. State
249 S.W.3d 680 (Court of Appeals of Texas, 2008)
Laster v. State
275 S.W.3d 512 (Court of Criminal Appeals of Texas, 2009)
Geesa v. State
820 S.W.2d 154 (Court of Criminal Appeals of Texas, 1991)
Olivarez v. State
171 S.W.3d 283 (Court of Appeals of Texas, 2005)
Brown v. State
911 S.W.2d 744 (Court of Criminal Appeals of Texas, 1995)
Evans v. State
202 S.W.3d 158 (Court of Criminal Appeals of Texas, 2006)
Watson v. State
861 S.W.2d 410 (Court of Appeals of Texas, 1993)
Paulson v. State
28 S.W.3d 570 (Court of Criminal Appeals of Texas, 2000)
Fisher v. State
887 S.W.2d 49 (Court of Criminal Appeals of Texas, 1994)
Oaks v. State
642 S.W.2d 174 (Court of Criminal Appeals of Texas, 1982)
Avila v. State
15 S.W.3d 568 (Court of Appeals of Texas, 2000)
Isassi v. State
330 S.W.3d 633 (Court of Criminal Appeals of Texas, 2010)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Humason v. State
728 S.W.2d 363 (Court of Criminal Appeals of Texas, 1987)
Humason v. State
699 S.W.2d 922 (Court of Appeals of Texas, 1985)
Gear v. State
340 S.W.3d 743 (Court of Criminal Appeals of Texas, 2011)

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