In Nevarez v. State, 767 S.W.2d 766, 768 (Tex. Crim. App. 1989), a co-defendant slid a bag containing marijuana over to Pacheco, an undercover officer. 79 Pacheco then took the bag and tore it open, 80 but the co-defendant refused to permit the him to completely remove the bag until after payment, which never occurred because the bust signal and arrest occurred shortly thereafter. The Court held that the defendant was properly convicted of an actual transfer pursuant to the law of parties. In its discussion, the Court cited a definition of "deliver" from Webster's Ninth Collegiate Dictionary and the Ballentine's Law Dictionary definition of "delivery" quoted in Daniels. While Nevarez did quote that part of Ballentine's that said a delivery can be accomplished by "making a thing available to another, placing it within his reach," the Court did not apply that definition to the facts of the case. Instead, the Court held that "the 'actual transfer' of the marihuana occurred pursuant to the law of parties the instant that Pacheco physically took and inspected the marihuana offered him by appellant's co-defendant." Despite the quote from Ballentine's, the Court did not say that sliding the contraband toward the recipient was enough to effectuate an actual transfer. Even if it had, sliding contraband close to the recipient is not the same as directing the recipient to contraband that is not immediately within reach. It is true that a physical taking of the contraband completes an actual transfer, but that does not exclude the possibility that a constructive transfer could occur beforehand, when the defendant directs the recipient to retrieve the contraband.