DEANDRE BROOKS v. UNITED STATES, 130 A.3d 952

Brooks was convicted of assaulting a police officer and possession of drug paraphernalia; the conviction for drug paraphernalia is challenged for insufficiency of evidence.
Police encountered Brooks and three men while pursuing robbery suspects; Brooks resisted arrest and assaulted an officer.
During a search incident to arrest, officers found a Bob Marley grinder in Brooks’s pants pocket, alleged to be used for grinding marijuana.
Narcotics officers testified grinders are commonly used to grind marijuana and that grinders often contain green plant material.
Defense presented no witnesses; the trial court convicted Brooks and explained the inference of intent from the grinder despite limited corroboration.
Brooks also moved for a continuance to allow plea negotiations; the court denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is there sufficient evidence of intent to use the grinder for drug-related purposes?	Brooks’s grinder is evidence of drug intent due to common use with marijuana and associates.	Brooks had no direct or circumstantial proof of drug-related intent; the grinder’s presence alone is insufficient.	No; insufficiency of evidence to prove intent beyond a reasonable doubt.
Did the trial court abuse its discretion by denying a continuance for plea negotiations?	Brooks sought more time for a global plea to resolve multiple cases.	Court should not delay trial for anticipated plea negotiations; no guaranteed benefit shown.	No abuse of discretion; denial of continuance affirmed.

Medley v. United States, 104 A.3d 115 (D.C. 2014) (standard for sufficiency review; evidence viewed in favor of the government)
(Sandra) Williams v. United States, 604 A.2d 420 (D.C. 1992) (intent can be inferred circumstantially from evidence around drug paraphernalia)
Rivas v. United States, 783 A.2d 125 (D.C. 2001) (sufficiency review; evidence must persuade beyond a reasonable doubt)
Crawford v. United States, 278 A.2d 125 (D.C. 1971) (possessing paraphernalia context; caution about reliance on single item)
Smith v. United States, 55 A.3d 884 (D.C. 2012) (settles standard for sufficiency and credibility in eyewitness/inferential proof)
Williams v. United States, 304 A.2d 287 (D.C. 1973) (earlier caution about relying on possession of a single item to prove intent)
Barnes v. United States, 760 A.2d 556 (D.C. 2000) (illustrates breadth of paraphernalia evidence inquiry)
United States v. Lyons, 448 A.2d 872 (D.C. 1982) (per curiam; evidentiary sufficiency considerations)
Fatumabahirtu v. United States, 26 A.3d 322 (D.C. 2011) (sufficiency where specific evidence supports drug-use inference)