Jonathon Knight v. State of Florida, 186 So. 3d 1005

Traffic stop of vehicle driven by Jonathon Knight; luggage with 24.4 grams of cannabis found on backseat; luggage tag identified Knight as owner.
K-9 alerted the passenger side; search occurred after Knight had been briefly removed then rejoined passengers; co-passenger Chad Harris remained in backseat near the suitcase.
Knight was charged with constructive possession (dominon/control and knowledge) and convicted of possession of >20 grams of cannabis; trial court denied motions for judgment of acquittal.
Fifth District affirmed, applying the circumstantial-evidence (reasonable-hypothesis-of-innocence) standard but also saying the regular sufficiency standard would produce the same result.
Florida Supreme Court retained the circumstantial-evidence standard but clarified it applies only when all evidence pointing to the defendant’s guilt is circumstantial (i.e., the defendant’s guilt is proven solely by circumstantial evidence).
Because testimony about the suitcase’s ownership was treated as direct evidence of dominion and control, the Court reviewed sufficiency de novo under the usual standard and affirmed Knight’s conviction as supported by competent, substantial evidence.

Issue	Knight's Argument	State's Argument	Held
Whether Florida should abandon the circumstantial-evidence (reasonable-hypothesis-of-innocence) standard of appellate review	Abandon or limit the special standard (argued by District discussion)	Retain the special standard; apply it where appropriate	Court declines to abandon the standard; retains it but narrows its scope
When the circumstantial-evidence standard applies	Applies only if any single element is proven solely by circumstantial evidence (per Fifth Dist. articulation)	Applies when the defendant’s guilt is shown only by circumstantial evidence (classic formulation)	Applies only where all evidence of the defendant’s guilt is circumstantial — i.e., the evidence tending to show the defendant committed the crime is entirely circumstantial
Sufficiency of evidence to sustain Knight’s constructive-possession conviction	Knight argued acquittal was required because knowledge could be explained by another (Harris) — circumstantial gap	State argued ownership of suitcase + circumstances allowed jury to infer knowledge and dominion	Because there was direct evidence of dominion/control (ownership tag) the special circumstantial standard did not apply; under the usual sufficiency review the evidence was sufficient and conviction affirmed

Jaramillo v. State, 417 So.2d 257 (Fla. 1982) (defines the circumstantial-evidence/ reasonable-hypothesis-of-innocence standard)
Dausch v. State, 141 So.3d 513 (Fla. 2014) (characterizes convictions based solely on circumstantial proof)
Knight v. State, 107 So.3d 449 (Fla. 2013) (Fifth DCA decision under review; affirmed by Fla. Sup. Ct.)
Evans v. State, 32 So.3d 188 (Fla. 1st DCA 2010) (constructive-possession reversal applying circumstantial standard)
Cook v. State, 571 So.2d 530 (Fla. 1st DCA 1990) (applies special standard where both elements were circumstantial)
E.H.A. v. State, 760 So.2d 1117 (Fla. 4th DCA 2000) (characterizes possession case as wholly circumstantial)
Davis v. State, 90 So.2d 629 (Fla. 1956) (discusses insufficiency where evidence yields only suspicion)
Mayo v. State, 71 So.2d 899 (Fla. 1954) (circumstantial evidence must be inconsistent with reasonable hypothesis of innocence)