## Facts

- Police executed a search warrant at an apartment leased by Antoine Abdel-Sater.
- Officers found about $16,500 in cash, a one-kilogram package of cocaine, and smaller quantities of cocaine in plastic bags.
- The kilogram package was found in a pair of jeans hanging on a utility-room door.
- About 9.6 grams of cocaine were found in a sports coat hanging in the bedroom closet.
- The apartment had two bedrooms, but only one appeared occupied; the landlord identified Abdel-Sater as the tenant and no other person was listed on the lease.
- After arrest and release on bail, Abdel-Sater surrendered an additional 81 grams of cocaine to police the next day; he was not charged for that 81 grams.
- He was tried for possession with intent to deliver cocaine in an amount greater than 400 grams; a jury convicted him and assessed 80 years’ imprisonment.

## Issues

1. Whether the evidence was legally sufficient to prove Abdel-Sater knowingly possessed the cocaine (including the kilogram found in the utility room) to support a conviction for possession with intent to deliver more than 400 grams.
2. Whether the trial court erred by restricting disclosure or inquiry into plea negotiations.
3. Whether challenged evidentiary rulings, including “opening the door” impeachment matters, required reversal.

## Decision

- The court affirmed the conviction and sentence.
- The evidence was sufficient because multiple affirmative links connected Abdel-Sater to the cocaine and supported knowing possession and intent to deliver.
- The trial court did not abuse its discretion in limiting plea-negotiation evidence, and no reversible evidentiary error was shown.

## Legal Principles

- When contraband is not found on the defendant’s person, the State may prove knowing possession through “affirmative links” showing the defendant’s connection to and control over the contraband, evaluated under the totality of the circumstances.
- Control of the premises (such as being the lessee and apparent sole occupant), location of drugs among the defendant’s clothing, large amounts of cash, and other incriminating conduct may collectively support constructive possession.
- Evidence is reviewed in the light most favorable to the verdict; the question is whether a rational factfinder could find the elements beyond a reasonable doubt.
- Plea negotiations are generally inadmissible; admission may depend on the purpose and foundation offered.
- A witness may “open the door” by creating a false or misleading impression, permitting otherwise inadmissible evidence to correct that impression, subject to the trial court’s discretion.

## Conclusion

The court upheld Abdel-Sater’s conviction for possession with intent to deliver more than 400 grams of cocaine, concluding that the State proved constructive possession through cumulative affirmative links tied to his control of the apartment and surrounding circumstances, and that the trial court’s limits on plea-negotiation evidence and related evidentiary matters did not warrant reversal.


Abdel-Sater v. State, 852 S.W.2d 671 (Tex. App.—Houston [14th Dist.] 1993, pet. ref'd)