Whether a reviewing court may uphold a conviction where the offense is defined by technical elements beyond the understanding of an ordinary factfinder if no evidence on the elements was presented at trial

QUESTION PRESENTED In 2015, the Texas Legislature made seeping revisions to how "controlled substances" are. defined in the drug possession statutes. Before the revisions, the statute implicated in this case— Section:481.1031 of the Texas Health & Safety Code, which defines a Penalty Group 2-A substance—was a list of prohibited substances. The problem, however, was that chemists would slightly alter one — of the listed substances, making it technically no longer the prohibited substance but nevertheless a dangerous one. With the legislature only meeting every two years, Texas law:was simply not able to keep up with clandestine chemists. The 2015 revisions were . the legislature's response. They did away with the list of drugs, | choosing instead to list several chemicals and detailing which molecular structures of the various listed chemicals (as they relate to one another) are prohibited. Consequently, Section 481.1031, is now, by necessary design, extremely complicated. In a published opinion, the court below inferred a substance met the molecular structural requirements of Section 481.1031 even though (by the court's admission), there was no direct evidence of that molecular structure in the record. This case, therefore, presents the following question: In a sufficiency analysis under Jackson v. virginia, 443 U.S. 307 (1979), may a reviewing court uphold a conviction where the ' offense is defined by technical elements beyond the understanding of an ordinary factfinder if no evidence on the elements was presented at trial? . . | i PARTIES TO THE PROCEEDINS BELOW This petition stems from a discretionary review proceeding in which Petitioner, Anthony Carter, was the before the Court of Criminal Appeals of Texas. Mr. Carter is a prisoner who was convicted of possession of a controlled substance with the intent to deliver in the 137th Judicial District Court , of Lubbock County, Texas, and he is in the custody of the State of Texas. The State of Texas was the Appellee before the Court of Criminal Appeals of Texas. Mr. Carter asks that the Court issue a Writ of Certiorari to the Court of Criminal Appeals of Texas. |