The case of State of Louisiana v. Richard Thomas Pigford involved the defendant being charged with possession of marijuana with intent to distribute. The defendant was found guilty by a jury, but the Second Circuit reversed the conviction due to lack of evidence proving constructive possession. The Supreme Court of Louisiana reversed the Second Circuit's decision, stating that the court of appeal erred by substituting its view of the evidence for that of the jury. The defendant's conviction and sentence were reinstated.

The defendant was driving an 18-wheeler on Interstate 20 in Caddo Parish when he was directed to pull over into the nearest weigh station due to being over the legal weight limit. Officers interviewed the defendant and discovered discrepancies in his story. The defendant refused to open the back of the trailer, citing his right to refuse a search as a member of the NAACP. An agent with the Public Service Commission arrived and informed the defendant that she had the right to inspect the trailer without his consent. The defendant produced a key and opened the trailer's doors. An officer climbed onto the back of the trailer to inspect the load and saw a large package in plain view. The package was wrapped in clear plastic wrap and duct tape and measured approximately a foot wide and six-and-a-half to seven feet long. The package was not visible from the agent's vantage point outside the trailer.

Deputy Williams found 52 pounds of marijuana worth $52,000 in a package after cutting a slit in it. The defendant argued that he was not aware of the marijuana in the trailer and suggested that it could have been loaded by someone else without his knowledge. The Second Circuit panel reversed the defendant's conviction because the state did not present enough evidence to prove that the defendant had knowledge of the marijuana found in the cargo area of the trailer. The question on review is whether the evidence presented at trial is sufficient to convince a rational trier of fact that all elements of the crime have been proven beyond a reasonable doubt. The appellate court cannot substitute its own appreciation of the evidence for that of the fact-finder.

The court of appeal reversed part of the decision but upheld the verdict because the defendant's claim of innocence was not reasonable. The defendant had control over the trailer and its contents, and it was only padlocked, allowing him access. Guilty knowledge is necessary to establish constructive possession of contraband, and it can be inferred from the circumstances of the transaction. Additional evidence was presented that could lead a rational trier of fact to infer the defendant's guilty knowledge of the marijuana found in the trailer, including his nervousness, deviation from the expected route, and lies about his destination. The defendant's conviction and sentence were reinstated.