A Texas court has upheld a 35-year prison sentence for Maximiano Gonzalez, who was found guilty of possessing methamphetamine with the intent to deliver. The Texas Court of Appeals, 7th District (Amarillo), ruled on May 26, 2026, affirming the decision of a lower court. This case highlights the legal complexities surrounding drug possession charges and the implications for defendants claiming a misunderstanding of their actions.

The court's ruling is significant for Gonzalez, who argued that he believed he was acting as a confidential informant for law enforcement. His conviction raises questions about the defenses available to individuals accused of drug-related offenses, particularly regarding claims of mistaken belief. The decision affects not only Gonzalez but also sets a precedent for future cases involving similar claims.

Background

Maximiano Gonzalez was charged with possession of methamphetamine with intent to deliver after a police officer discovered him in a commercial location in Lubbock, Texas, in June 2022. Officer Justin Criner, responding to an eviction, found Gonzalez asleep on a couch surrounded by drug paraphernalia and packets of methamphetamine. The officer weighed the drugs, which amounted to approximately 117 grams.

During the encounter, Gonzalez claimed he was a confidential informant working for Captain Tony Williams of the Lubbock Police Department. However, Captain Williams confirmed to Officer Criner that Gonzalez was not an informant and directed the officer to arrest him. The situation escalated as Gonzalez tried to convince the officer he was gathering drugs for law enforcement, a claim that the officer found inconsistent with the behavior of legitimate informants.

Gonzalez was subsequently indicted and tried for the possession charge. At trial, he did not dispute that he possessed the methamphetamine but contended that he lacked the intent to deliver it, believing instead that he was acting in cooperation with law enforcement. His defense attorney argued for a lesser charge of simple possession, claiming that Gonzalez's belief negated the intent required for a conviction of possession with intent to deliver.

The Ruling

The Texas Court of Appeals ruled against Gonzalez on two main issues he raised during his appeal. First, he claimed the trial court erred by denying his request for a mistake-of-fact jury instruction, which would have allowed the jury to consider his belief that he was acting as an informant. The court found that the trial court did not abuse its discretion in denying this request.

The court ruled, “Appellant’s claimed mistake does not negate that he ‘knowingly ... possesse[d] with intent to deliver a controlled substance.’”

The court explained that the mistake-of-fact defense applies only to elements requiring proof of a culpable mental state. In this case, the court stated that Gonzalez’s belief did not negate the knowledge required to be convicted of possession with intent to deliver.

Additionally, the court reviewed Gonzalez's motion for a mistrial, which he filed after the jury sent notes asking about his prior convictions and time served. The court concluded that the trial court did not abuse its discretion in denying the mistrial motion, emphasizing that jurors are presumed to follow instructions given by the court.

The court noted, “A mistrial is a device used to halt trial proceedings when error is so prejudicial that expenditure of further time and expense would be wasteful and futile.”

Impact

This ruling has significant implications for individuals facing drug possession charges in Texas. It clarifies the limitations of the mistake-of-fact defense, particularly in cases involving possession with intent to deliver. The court's decision reinforces the notion that a defendant's subjective belief about their status as an informant does not exempt them from liability if they knowingly possess illegal substances.

Moreover, the ruling may influence how lower courts handle similar cases in the future, particularly regarding jury instructions and the criteria for granting mistrials. This case sets a precedent that could impact other defendants who may try to claim a misunderstanding of their actions in drug-related offenses.

What's Next

Gonzalez's legal options moving forward are limited. The court's ruling can be appealed to the Texas Court of Criminal Appeals, but it is uncertain if that will happen. There are no related cases pending that would directly influence this decision.