FILED JULY 9, 2026 In the Office of the Clerk of Court WA State Court of Appeals, Division III
IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE
STATE OF WASHINGTON, ) ) No. 40582-6-III Respondent, ) ) v. ) ) TRAVIS JASON STOUGH, ) UNPUBLISHED OPINION ) Appellant. )
COONEY, J. — Travis Stough was convicted of possession of cocaine and
possession of methamphetamine with intent to deliver. Mr. Stough appeals his
conviction for possession of methamphetamine with intent to deliver, arguing the State
presented insufficient evidence to support the conviction. Mr. Stough also filed a
statement of additional grounds for review (SAG) raising two issues. We disagree with
each argument and affirm.
BACKGROUND
Mr. Stough and Stephanie Olson 1 were romantically involved until May 2023
and would often use methamphetamine together. Mr. Stough was a regular
1 She also goes by “Ms. Anderson” and “Stormy;” we refer to her as “Ms. Olson” for clarity. No. 40582-6-III State v. Stough
methamphetamine user who would often consume an “eight-ball,” (about 3.5 grams) of
methamphetamine daily or every few days. Verbatim Rep. of Proc. (VRP) at 784, 787-
88. After their relationship ended, Ms. Olson contacted the Grays Harbor County Drug
Task Force to inquire about working as a confidential informant to “tak[e] care of” a
burglary charge she “was facing.” VRP at 660.
Under the supervision of the Grays Harbor County Drug Task Force, Ms. Olson
purchased methamphetamine from Mr. Stough on three separate occasions at his
residence in Ocean City, Washington. Detective Ryan Tully used information from these
purchases to obtain a search warrant for Mr. Stough’s residence. A subsequent search of
Mr. Stough’s residence yielded two vacuum sealed bags that had been cut open, one with
the number “52” written on it, a “baggy of suspected methamphetamine” weighing 3.46
grams, hypodermic needles, a digital scale, and “various bags.” 2 VRP at 475, 481, 628.
Law enforcement discovered 4.5 grams of suspected cocaine in Mr. Stough’s pocket
when he was later arrested.
Relevant to this appeal, Mr. Stough was charged with possession of
methamphetamine with intent to deliver based on law enforcement discovering
2 These “various bags” were also referred to as “baggies” and “[Z]iplock bags.” See, e.g., VRP at 475, 488, 479.
2 No. 40582-6-III State v. Stough
methamphetamine and a panoply of drug-related items in his home. 3 Trial commenced
on May 15, 2025.
At trial, Detective Tully testified that he was employed by the Grays Harbor
County Sheriff’s Office and assigned to the Drug Task Force. His experience
investigating drug-related crimes consisted of his previous employment with Pacific
County’s Drug Task Force, completion of the Drug Enforcement Administration’s basic
academy, and continued routine attendance at conferences and trainings related to drug
investigations.
Detective Tully testified, based on his training and experience, that (1) vacuum
sealed bags are typically used to condense controlled substances so the product can fit in
smaller spaces, (2) the number “52” written on the one of the vacuum sealed bags was “a
number the Mexican cartels use to kind of mark their product,” (3) “[s]cales are used in
drug trafficking cases in weighing [the] drugs” to ensure “the drug dealer knows that they
are not giving away too much of their product,” and (4) the baggies were “consistent with
packaging material” used for the sale of drugs. VRP at 481-82, 488.
Detective Tully testified he executed a search warrant at Mr. Stough’s residence
where he found a lockbox containing “a baggy of suspected methamphetamine . . . some
3 The State also charged Mr. Stough with three counts of delivery of a controlled substance from Ms. Olson’s controlled buys. The trial court dismissed the three counts on the State’s motion.
3 No. 40582-6-III State v. Stough
hypodermic needles . . . and just—just some various bags.” VRP at 470, 475. He
testified that he has “seized methamphetamine hundreds of times in [his] career [and] this
is consistent with the same substance [he has] seen.” VRP at 477. Detective Tully
confirmed Ziplock bags were found and seized in Mr. Stough’s residence because “[b]ags
like this are, in [his] training and experience, are indicative of drug sales.” VRP at 479-
80. The bags were small and “consistent with [the] baggies that were used during the
controlled purchases.” VRP at 489. Detective Tully admitted he did not find any money
or “crib notes” 4 during the search. VRP at 567.
Ms. Olson testified about her participation in the “operation with the Drug Task
Force over the course of the summer of 2023.” VRP at 663. She testified Mr. Stough
had previously delivered methamphetamine to her “maybe 20” times, and she had gone to
his house to buy methamphetamine “probably about 15 times.” VRP at 666-68. She
stated Mr. Stough kept the methamphetamine inside a “metal lockbox.” VRP at 682.
When she procured methamphetamine, Mr. Stough would take some out, weigh it, and
put it in a sandwich bag for her.
Mr. Stough testified that he used methamphetamine daily during the spring and
summer of 2023. Although Mr. Stough admitted to routinely purchasing drugs, he
denied purchasing drugs with the intent of selling the drugs and denied ever selling drugs.
4 “Crib notes” are written transactions commonly kept by drug dealers.
4 No. 40582-6-III State v. Stough
Mr. Stough testified, “Typically, I have probably an eight-ball, which would last me—
depending on the day, it could last me for a day.” VRP at 787. He also stated he
portioned his drugs so he would only use one-half gram at a time in an effort to save
money. He claimed the methamphetamine found in his home was for personal use.
Ultimately, the jury found Mr. Stough guilty of possession of cocaine 5 and
possession of methamphetamine with intent to deliver.
Mr. Stough timely appeals.
ANALYSIS
SUFFICIENCY OF EVIDENCE
Mr. Stough argues insufficient evidence was presented for the jury to convict him
of possession of methamphetamine with intent to deliver. We disagree.
The sufficiency of the evidence is a question of law this court reviews de novo.
State v. Rich, 184 Wn.2d 897, 903, 365 P.3d 746 (2016). In a sufficiency of the evidence
challenge, “we review the evidence in the light most favorable to the State to determine
‘whether . . . any rational trier of fact could have found guilt beyond a reasonable
doubt.’” State v. Varga, 151 Wn.2d 179, 201, 86 P.3d 139 (2004) (quoting State v.
Salinas, 119 Wn.2d 192, 201, 829 P.2d 1068 (1992)). “A claim of insufficiency admits
5 The State charged Mr. Stough with possession of cocaine with intent to deliver. The jury found him guilty of the lesser included offense of possession of cocaine.
5 No. 40582-6-III State v. Stough
the truth of the State’s evidence and all inferences that can reasonably be drawn from it.”
State v. DeVries, 149 Wn.2d 842, 849, 72 P.3d 748 (2003). We can infer criminal intent
from the defendant’s conduct, and circumstantial evidence and direct evidence carry
equal weight.
Free access — add to your briefcase to read the full text and ask questions with AI
FILED JULY 9, 2026 In the Office of the Clerk of Court WA State Court of Appeals, Division III
IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE
STATE OF WASHINGTON, ) ) No. 40582-6-III Respondent, ) ) v. ) ) TRAVIS JASON STOUGH, ) UNPUBLISHED OPINION ) Appellant. )
COONEY, J. — Travis Stough was convicted of possession of cocaine and
possession of methamphetamine with intent to deliver. Mr. Stough appeals his
conviction for possession of methamphetamine with intent to deliver, arguing the State
presented insufficient evidence to support the conviction. Mr. Stough also filed a
statement of additional grounds for review (SAG) raising two issues. We disagree with
each argument and affirm.
BACKGROUND
Mr. Stough and Stephanie Olson 1 were romantically involved until May 2023
and would often use methamphetamine together. Mr. Stough was a regular
1 She also goes by “Ms. Anderson” and “Stormy;” we refer to her as “Ms. Olson” for clarity. No. 40582-6-III State v. Stough
methamphetamine user who would often consume an “eight-ball,” (about 3.5 grams) of
methamphetamine daily or every few days. Verbatim Rep. of Proc. (VRP) at 784, 787-
88. After their relationship ended, Ms. Olson contacted the Grays Harbor County Drug
Task Force to inquire about working as a confidential informant to “tak[e] care of” a
burglary charge she “was facing.” VRP at 660.
Under the supervision of the Grays Harbor County Drug Task Force, Ms. Olson
purchased methamphetamine from Mr. Stough on three separate occasions at his
residence in Ocean City, Washington. Detective Ryan Tully used information from these
purchases to obtain a search warrant for Mr. Stough’s residence. A subsequent search of
Mr. Stough’s residence yielded two vacuum sealed bags that had been cut open, one with
the number “52” written on it, a “baggy of suspected methamphetamine” weighing 3.46
grams, hypodermic needles, a digital scale, and “various bags.” 2 VRP at 475, 481, 628.
Law enforcement discovered 4.5 grams of suspected cocaine in Mr. Stough’s pocket
when he was later arrested.
Relevant to this appeal, Mr. Stough was charged with possession of
methamphetamine with intent to deliver based on law enforcement discovering
2 These “various bags” were also referred to as “baggies” and “[Z]iplock bags.” See, e.g., VRP at 475, 488, 479.
2 No. 40582-6-III State v. Stough
methamphetamine and a panoply of drug-related items in his home. 3 Trial commenced
on May 15, 2025.
At trial, Detective Tully testified that he was employed by the Grays Harbor
County Sheriff’s Office and assigned to the Drug Task Force. His experience
investigating drug-related crimes consisted of his previous employment with Pacific
County’s Drug Task Force, completion of the Drug Enforcement Administration’s basic
academy, and continued routine attendance at conferences and trainings related to drug
investigations.
Detective Tully testified, based on his training and experience, that (1) vacuum
sealed bags are typically used to condense controlled substances so the product can fit in
smaller spaces, (2) the number “52” written on the one of the vacuum sealed bags was “a
number the Mexican cartels use to kind of mark their product,” (3) “[s]cales are used in
drug trafficking cases in weighing [the] drugs” to ensure “the drug dealer knows that they
are not giving away too much of their product,” and (4) the baggies were “consistent with
packaging material” used for the sale of drugs. VRP at 481-82, 488.
Detective Tully testified he executed a search warrant at Mr. Stough’s residence
where he found a lockbox containing “a baggy of suspected methamphetamine . . . some
3 The State also charged Mr. Stough with three counts of delivery of a controlled substance from Ms. Olson’s controlled buys. The trial court dismissed the three counts on the State’s motion.
3 No. 40582-6-III State v. Stough
hypodermic needles . . . and just—just some various bags.” VRP at 470, 475. He
testified that he has “seized methamphetamine hundreds of times in [his] career [and] this
is consistent with the same substance [he has] seen.” VRP at 477. Detective Tully
confirmed Ziplock bags were found and seized in Mr. Stough’s residence because “[b]ags
like this are, in [his] training and experience, are indicative of drug sales.” VRP at 479-
80. The bags were small and “consistent with [the] baggies that were used during the
controlled purchases.” VRP at 489. Detective Tully admitted he did not find any money
or “crib notes” 4 during the search. VRP at 567.
Ms. Olson testified about her participation in the “operation with the Drug Task
Force over the course of the summer of 2023.” VRP at 663. She testified Mr. Stough
had previously delivered methamphetamine to her “maybe 20” times, and she had gone to
his house to buy methamphetamine “probably about 15 times.” VRP at 666-68. She
stated Mr. Stough kept the methamphetamine inside a “metal lockbox.” VRP at 682.
When she procured methamphetamine, Mr. Stough would take some out, weigh it, and
put it in a sandwich bag for her.
Mr. Stough testified that he used methamphetamine daily during the spring and
summer of 2023. Although Mr. Stough admitted to routinely purchasing drugs, he
denied purchasing drugs with the intent of selling the drugs and denied ever selling drugs.
4 “Crib notes” are written transactions commonly kept by drug dealers.
4 No. 40582-6-III State v. Stough
Mr. Stough testified, “Typically, I have probably an eight-ball, which would last me—
depending on the day, it could last me for a day.” VRP at 787. He also stated he
portioned his drugs so he would only use one-half gram at a time in an effort to save
money. He claimed the methamphetamine found in his home was for personal use.
Ultimately, the jury found Mr. Stough guilty of possession of cocaine 5 and
possession of methamphetamine with intent to deliver.
Mr. Stough timely appeals.
ANALYSIS
SUFFICIENCY OF EVIDENCE
Mr. Stough argues insufficient evidence was presented for the jury to convict him
of possession of methamphetamine with intent to deliver. We disagree.
The sufficiency of the evidence is a question of law this court reviews de novo.
State v. Rich, 184 Wn.2d 897, 903, 365 P.3d 746 (2016). In a sufficiency of the evidence
challenge, “we review the evidence in the light most favorable to the State to determine
‘whether . . . any rational trier of fact could have found guilt beyond a reasonable
doubt.’” State v. Varga, 151 Wn.2d 179, 201, 86 P.3d 139 (2004) (quoting State v.
Salinas, 119 Wn.2d 192, 201, 829 P.2d 1068 (1992)). “A claim of insufficiency admits
5 The State charged Mr. Stough with possession of cocaine with intent to deliver. The jury found him guilty of the lesser included offense of possession of cocaine.
5 No. 40582-6-III State v. Stough
the truth of the State’s evidence and all inferences that can reasonably be drawn from it.”
State v. DeVries, 149 Wn.2d 842, 849, 72 P.3d 748 (2003). We can infer criminal intent
from the defendant’s conduct, and circumstantial evidence and direct evidence carry
equal weight. Varga, 151 Wn.2d at 201. However, “inferences based on circumstantial
evidence must be reasonable and cannot be based on speculation.” State v. Vasquez, 178
Wn.2d 1, 16, 309 P.3d 318 (2013). We defer to the trier of fact on issues of conflicting
testimony, witness credibility, and the persuasiveness of evidence. State v. Thomas, 150
Wn.2d 821, 874-75, 83 P.3d 970 (2004).
Mr. Stough argues the State failed to present sufficient evidence that he intended
to deliver the methamphetamine found in his home.
The elements of possession of a controlled substance with intent to deliver are
(1) unlawful possession, (2) with intent to deliver, (3) a controlled substance. RCW
69.50.401(1). Regardless of the quantity of a controlled substance, Washington law
forbids inferring intent to deliver from mere possession of controlled substances alone.
State v. Brown, 68 Wn. App. 480, 483-84, 843 P.2d 1098 (1993). Rather, the possession
must be accompanied by at least one additional factor suggesting an intent to deliver.
State v. Hagler, 74 Wn. App. 232, 236, 872 P.2d 85 (1994). Although not exclusive, an
additional factor may include the possession of money, scales, or sales records. See, e.g.,
State v. Hotchkiss, 1 Wn. App. 2d 275, 280-81, 404 P.3d 629 (2017) ($2,150 in a safe
next to 8.1 grams of methamphetamine); State v. Lane, 56 Wn. App. 286, 297-98, 786
6 No. 40582-6-III State v. Stough
P.2d 277 (1989) (possession of cocaine, a scale, and $850); State v. Campos, 100 Wn.
App. 218, 224, 998 P.2d 893 (2000) (possession of one ounce of cocaine coupled with
$1,750 and a record of sales).
Here, Mr. Stough does not challenge that he unlawfully possessed
methamphetamine, a controlled substance. Rather, he claimed at trial that the
methamphetamine was for his personal use. He insinuated the scale was used to ration
and divide the methamphetamine into daily quantities in baggies to conserve money.
Although Mr. Stough’s testimony is plausible, it does not meet the test we apply to a
sufficiency of the evidence challenge.
In reviewing the evidence in a light most favorable to the State, sufficient evidence
was admitted at trial to prove Mr. Stough possessed methamphetamine with the intent to
deliver the methamphetamine. In a sufficiency of evidence challenge, this court must
accept the State’s evidence as true. In applying this principle, Detective Tully’s
testimony provides more than one additional factor, in addition to the presence of
methamphetamine, evincing an intent to deliver. Accepting Detective Tully’s testimony
as true, the vacuum sealed bags, the number “52” written on one of the bags, the digital
scale, and the “various bags” commonly used to deliver controlled substances were
indicative of drug sales. VRP at 481, 475. Even though this evidence may also be
consistent with Mr. Stough’s claimed personal use, “it is the duty of the fact finder, not
7 No. 40582-6-III State v. Stough
the appellate court, to weigh the evidence.” State v. Goodman, 150 Wn.2d 774, 783, 83
P.3d 410 (2004).
Based on Mr. Stough’s admitted possession of methamphetamine in conjunction
with Detective Tully’s testimony, any rational trier of fact could have found beyond a
reasonable doubt that Mr. Stough possessed the methamphetamine with intent to deliver
the methamphetamine. Thus, sufficient evidence supports the conviction.
STATEMENT OF ADDITIONAL GROUNDS FOR REVIEW
RAP 10.10 permits a defendant to file a SAG if he believes his appellate counsel
has not adequately addressed certain matters. Mr. Stough filed a SAG raising two issues.
Mr. Stough first argues that a dashboard or body worn camera recording was not
admitted into evidence and that he was not given the opportunity to review the recording.
He contends there is evidence on the recording that “would have changed the way the
trial went.” SAG at 1.
We decline to review this issue. We cannot consider evidence outside the record
on direct review; the proper way to address matters outside the record is through a
personal restraint petition. State v. McFarland, 127 Wn.2d 322, 335, 899 P.2d 1251
(1995).
Mr. Stough next argues that the lead investigator, presumably Detective Tully, was
the only witness allowed to remain in the courtroom throughout the trial. He contends
8 No. 40582-6-III State v. Stough
the lead investigator was able to use the knowledge he gained from hearing other
witnesses testify to make his testimony more effective and that it is “not fair.” SAG at 1.
Because Mr. Stough’s SAG is unsupported by any reasoned argument or citation
to relevant legal authority, we decline review of his claimed error. West v. Thurston
County, 168 Wn. App. 162, 187, 275 P.3d 1200 (2012) (Passing treatment of an issue or
lack of reasoned argument is insufficient to merit this court’s consideration.).
Affirmed.
A majority of the panel has determined this opinion will not be printed in
the Washington Appellate Reports, but it will be filed for public record pursuant to
RCW 2.06.040.
Cooney, J.
WE CONCUR:
Staab, C.J.
Lawrence-Berrey, J.