TINA MARIE WRIGHT A/K/A TINA MARIE NAGEL v. THE STATE OF TEXAS
201 S.W.3d 765
Procedural History: Defendant Tina Marie Wright aka Tina Marie Nagel was convicted of
possession of methamphetamine of less than 400 grams but more than 200 grams in a jury trial in
Taylor County. The inclusion of toxic liquids within the aggregate weight of the controlled
substance was deemed as a drug mixture, according to the definition of § 481.002 Texas Health
& Safety Code. Although there was a testimony that the defendant possessed less than one gram
of “pure” methamphetamine, Wright was convicted in 2001 and sentenced to imprisonment for
life. The defendant made two appeals, one with the Court of Appeals, which was affirmed, and
another with the Court of Criminal Appeals, which was vacated and remanded for further
consideration. After further consideration, the Court of Appeals affirmed again, and the
defendant petitioned for discretionary review.
Issue: Did the inclusion of unusable toxic liquids in the weight of a control substance, as per the
definition in § 481.002 Texas Health & Safety Code, lead to an absurd result given that the
defendant had possessed less than one gram of actual or “pure” methamphetamine.
Rule: Regarding statutes, it should be interpreted literally, unless it leads to an absurd result to
where the legislature could not have intended. If the statute’s plain language has a possibility of
being ambiguous and/or leading to absurd results, the courts may consider outside factors such as
legislative history or administrative interpretations to come to a reasonable interpretation.
201 S.W.3d 765
Procedural History: Defendant Tina Marie Wright aka Tina Marie Nagel was convicted of
possession of methamphetamine of less than 400 grams but more than 200 grams in a jury trial in
Taylor County. The inclusion of toxic liquids within the aggregate weight of the controlled
substance was deemed as a drug mixture, according to the definition of § 481.002 Texas Health
& Safety Code. Although there was a testimony that the defendant possessed less than one gram
of “pure” methamphetamine, Wright was convicted in 2001 and sentenced to imprisonment for
life. The defendant made two appeals, one with the Court of Appeals, which was affirmed, and
another with the Court of Criminal Appeals, which was vacated and remanded for further
consideration. After further consideration, the Court of Appeals affirmed again, and the
defendant petitioned for discretionary review.
Issue: Did the inclusion of unusable toxic liquids in the weight of a control substance, as per the
definition in § 481.002 Texas Health & Safety Code, lead to an absurd result given that the
defendant had possessed less than one gram of actual or “pure” methamphetamine.
Rule: Regarding statutes, it should be interpreted literally, unless it leads to an absurd result to
where the legislature could not have intended. If the statute’s plain language has a possibility of
being ambiguous and/or leading to absurd results, the courts may consider outside factors such as
legislative history or administrative interpretations to come to a reasonable interpretation.
