This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant was convicted of possession of methamphetamine and drug paraphernalia after police, acting on a tip, searched a mobile home where she resided with her boyfriend. Methamphetamine and paraphernalia were found in a shared bedroom dresser. The Defendant denied ownership, claiming the items belonged solely to her boyfriend, who supported her claim. However, evidence suggested shared control, including duplicate paraphernalia sets and the Defendant's admission of prior drug use with her boyfriend (paras 2-5, 10-12).
Procedural History
- District Court of San Juan County: The Defendant was convicted of possession of methamphetamine and drug paraphernalia.
Parties' Submissions
- Appellant (Defendant): Argued that the evidence was insufficient to prove constructive possession, as she lacked exclusive control over the bedroom and the drugs belonged solely to her boyfriend. She also contended that the trial court erred in admitting evidence of drug possession by other mobile home occupants, claiming it was irrelevant and prejudicial under Rules 11-403 and 11-404(B) (paras 1, 6, 16-17).
- Appellee (State): Asserted that the Defendant had joint constructive possession of the drugs and paraphernalia based on circumstantial evidence, including her knowledge of the items and shared control of the dresser. The State also argued that evidence of other occupants' drug possession was relevant to establish the mobile home as a "drug house" and to infer the Defendant's knowledge of the drugs in her room (paras 5, 6, 27-28).
Legal Issues
- Was there sufficient evidence to support the Defendant's conviction for constructive possession of methamphetamine and drug paraphernalia?
- Did the trial court err in admitting evidence of drug possession by other mobile home occupants under Rules 11-403 and 11-404(B)?
Disposition
- The Court of Appeals affirmed the Defendant's convictions (para 33).
Reasons
Per Bosson J. (Wechsler and Sutin JJ. concurring):
Constructive Possession: The Court found sufficient evidence to support the Defendant's conviction. Constructive possession requires knowledge and control over the contraband. Although the Defendant shared the bedroom with her boyfriend, additional circumstances, such as duplicate paraphernalia sets and her admission of prior drug use, supported the inference of joint possession. The jury was entitled to disbelieve the Defendant's claim of ignorance and infer shared control over the dresser's contents (paras 8-15).
Evidentiary Issues (Rule 11-404(B)): The Court held that the Defendant failed to preserve her objection under Rule 11-404(B) because she did not raise it explicitly at trial. The motion in limine and trial arguments focused on Rule 11-403, not the prohibition of character evidence under Rule 11-404(B). The Court declined to consider this issue further (paras 16-23).
Evidentiary Issues (Rule 11-403): The Court found no abuse of discretion in admitting evidence of drug possession by other mobile home occupants. This evidence was relevant to establish the Defendant's knowledge of the drugs in her room and to characterize the mobile home as a "drug house." While the probative value was marginal, it was not substantially outweighed by the risk of unfair prejudice, especially given the Defendant's own admissions of drug use and association with drug users (paras 24-29).
Prosecutorial Conduct: The Court criticized the prosecution's closing argument, which emphasized the mobile home as a "drug house" and invoked inflammatory rhetoric about "peddling poison." However, the Defendant did not object to these remarks at trial, and the Court found no fundamental error warranting reversal. The evidence supporting the conviction was sufficient to ensure a fair trial (paras 30-32).