## Facts

- Sixteen-year-old L.G. was videotaped during school hours on private property near her high school while she and two other girls engaged in conduct consistent with snorting cocaine.
- Authorities did not recover any of the powdery substance seen on the videotape, and no chemical testing was performed.
- At the adjudication hearing, one of the other girls testified that L.G. said she had cocaine and that the girls decided to “sniff” or “snort” it.
- A jury found L.G. engaged in delinquent conduct by knowingly or intentionally possessing cocaine.
- At disposition, the only evidence in the record addressing L.G.’s background and placement needs was a juvenile probation report.
- The probation report recommended probation and reported favorable circumstances, including no prior juvenile referrals, a stable family situation, a stable school record, and involvement in extracurricular activities; it rated her prognosis for completing probation as good.
- The trial court’s original adjudication-and-disposition order committed L.G. to the Texas Youth Commission (TYC) but did not state reasons for choosing that placement.
- After L.G. requested a statement of reasons, the trial court signed an adjudication-and-disposition order nunc pro tunc listing reasons that largely repeated offense circumstances (use of cocaine; proximity to the high school; public view; acquisition in a classroom; involving other students).
- On an earlier appeal, the court of appeals remanded with instructions for the trial court to state reasons for the disposition.
- On remand, the trial court entered an amended order that was nearly identical to the nunc pro tunc order, adding that there was great local concern about a community and school drug problem.
- L.G. appealed again, challenging both the adjudication evidence and the sufficiency of the stated reasons supporting commitment to TYC.

## Issues

1. Whether the evidence was legally sufficient to support the jury’s finding that L.G. knowingly or intentionally possessed cocaine, despite the absence of recovered contraband or laboratory analysis.
2. Whether the dispositional order committing L.G. to TYC satisfied Texas juvenile-law requirements to state reasons for the chosen disposition that are supported by the dispositional evidence, rather than merely repeating offense details and general community concerns.

## Decision

- The court affirmed the portion of the judgment adjudicating that L.G. engaged in delinquent conduct by possessing cocaine.
- The court vacated the remainder of the judgment, including the commitment to TYC, because the trial court’s stated reasons did not satisfy the statutory requirement for a reviewable, evidence-based statement of reasons for disposition.
- The case was returned to the trial court for further proceedings consistent with the opinion as to disposition.

## Legal Principles

- Legal sufficiency in a juvenile drug-possession adjudication may be met through testimony and circumstances from which the factfinder can infer knowing possession of a controlled substance, even if no substance is recovered and no chemical analysis is introduced.
- A dispositional order committing a juvenile to TYC must include stated reasons for the specific disposition so that an appellate court can review whether the placement is justified by the child’s circumstances and the record.
- A statement of reasons that mainly restates the facts of the offense, or relies on generalized community concern about drugs, does not adequately explain why commitment is necessary for that child as opposed to a less restrictive alternative.
- When the dispositional record contains evidence favoring probation (such as a favorable probation report and no prior referrals), the court’s reasons must address why probation is not appropriate and why commitment is required.

## Conclusion

The court of appeals upheld L.G.’s adjudication for possessing cocaine based on the evidence presented at trial, but it vacated the commitment to TYC because the trial court’s written reasons were largely a repetition of offense allegations plus general local drug concerns and were not tied to the dispositional evidence supporting an individualized placement decision.


In the Matter of L.G., 728 S.W.2d 939 (1987)