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 stopped by a police officer for driving a vehicle with an expired registration sticker. During the stop, the officer discovered that the Defendant had an outstanding warrant and a revoked driver’s license. The Defendant was arrested, and a search incident to arrest revealed a small glass bottle containing white powder in his pants pocket, which tested positive for methamphetamine. A subsequent search at the jail uncovered a small baggie with a white substance that also tested positive for methamphetamine (paras headnotes, para 4).
Procedural History
- District Court, Curry County: The Defendant was convicted of one count of possession of methamphetamine.
Parties' Submissions
- Defendant-Appellant: Argued that the evidence presented at trial was insufficient to support a conviction for possession of a controlled substance. Cited State v. Franklin and State v. Boyer to support the contention that the evidence did not establish possession beyond a reasonable doubt (paras headnotes, para 2).
- Plaintiff-Appellee: Asserted that the evidence, including the officer’s testimony and the positive field tests for methamphetamine, was sufficient to support the conviction.
Legal Issues
- Was there sufficient evidence to support the Defendant’s conviction for possession of methamphetamine?
Disposition
- The Court of Appeals affirmed the Defendant’s conviction for possession of methamphetamine.
Reasons
Per Kennedy J. (Bustamante and Vigil JJ. concurring):
The Court applied the two-step process for sufficiency of evidence review, viewing the evidence in the light most favorable to the verdict and determining whether a rational trier of fact could find each element of the crime established beyond a reasonable doubt. The jury instructions required proof that the Defendant knowingly possessed methamphetamine or believed it to be a regulated or prohibited substance. The officer’s testimony, the discovery of methamphetamine on the Defendant’s person, and the positive field tests provided sufficient evidence to support the jury’s finding. The Court concluded that the evidence met the legal standard for sufficiency and affirmed the conviction.