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Louisiana Supreme Court - 922 So. 2d 517
Tags: Criminal law, Possession
tl;dr:
Circumstantial evidence can support a conviction for possession with intent to distribute where other hypotheses are not probable.Video Summary
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The defendant was initially found guilty of possession of marijuana with intent to distribute, but the Second Circuit reversed the conviction due to lack of evidence proving constructive possession. The Supreme Court found that the court of appeal erred by substituting its view of the evidence for that of the jury and reinstated the conviction and sentence. The defendant was pulled over for exceeding the legal weight limit while driving a truck and was asked to open the back for inspection. After refusing, an agent was called to inspect the trailer without consent, and a large package of marijuana was found in plain view. The defendant denied knowledge of the package, but it was seized as evidence. The court of appeal reversed part of the decision on the grounds that the state failed to disprove the possibility that the defendant mistakenly took the wrong trailer, but this alternative hypothesis was not probable enough to create reasonable doubt. The defendant's hypothesis of innocence was also rejected because he had control over the trailer and its contents, and it was only padlocked, not sealed. Therefore, the defendant had ample opportunity to know about the marijuana and was not innocent.
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