Legend autopositioning currently does not take text objects into account as can be checked by running

plt.plot([0, 1], label="foo"); plt.text(.05, .95, "a"); plt.legend()

This is because text objects are not included in _auto_legend_data (which only serves that purpose, AFAICT).

Adding them should be easy, but extra points if the autoplacement algorithm penalizes overlapping with text more than overlapping with other artists (given that it's probably indeed worse in general).