Possession of Cocaine

In Campbell v. State, the Texas Court of Criminal Appeals reversed a conviction of possession of cocaine in an amount of 4 grams or more, but less than 200 grams.  The jury found 2 enhancement paragraphs true and assessed punishment at 99 years in prison.  The court of appeals held that the appellant’s notice of appeal was untimely filed and dismissed for want of jurisdiction.

However, the Criminal Appellate court held that the mailbox rule applies to incarcerated appellants and, as such, the pleadings of the pro se inmates shall be deemed filed at the time they are delivered to prison authorities for forwarding to the court clerk.