Knight v. State
2013 Fla. App. LEXIS 744
| Fla. Dist. Ct. App. | 2013Background
- Knight was convicted of possession of cannabis over 20 grams after police found 24.4 grams in a suitcase in his car; the suitcase bore his name and tag and was in the passenger compartment.
- A K-9 unit alerted to the suitcase area; Deputy Murphy seized the suitcase and cannabis, which tested positive for cannabis.
- Knight denied ownership of the cannabis and suggested Chad Harris could have placed it in the suitcase; Miller testified Harris had access but did not place it.
- Knight’s friend Miller testified the cannabis did not belong to Knight and Harris could have placed it there; Knight testified he did not sell drugs and that money was for weekend expenses.
- The jury found Knight guilty of possession of more than 20 grams and not guilty of possession with intent to sell or deliver; Knight moved for judgment of acquittal, which was denied.
- The trial court and appellate court considered whether the knowledge element could be proven by circumstantial evidence and which standard of review applies to circumstantial versus direct evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review for circumstantial evidence | Knight argues the special circumstantial standard requires reversal. | State relies on traditional sufficiency review with direct/circumstantial mix. | The court rejects the special standard; affirms under rational-trier-of-fact standard. |
| Knowledge element in constructive possession | Knight asserts Harris could have placed the cannabis in the luggage without his knowledge. | State can prove knowledge by circumstantial evidence given Knight’s dominion over the suitcase. | Knowledge is a jury question; conviction affirmed because dominion and control shown and hypotheses of innocence contested. |
| Whether the special standard should apply to this case | Applying the special standard would require reversal. | Standard applies only when all evidence is circumstantial; not applicable here. | Special standard not applicable; not wholly circumstantial; substantial direct evidence supports conviction. |
Key Cases Cited
- Pagan v. State, 830 So.2d 792 (Fla.2002) (standard of review for sufficiency—view evidence in light favorable to State)
- Law v. State, 559 So.2d 187 (Fla.1989) (special circumstantial standard discussed and criticized)
- Jaramillo v. State, 417 So.2d 257 (Fla.1982) (Florida eliminated Webster-type instruction; circumstantial review context)
- Holland v. United States, 348 U.S. 121 (U.S.1984) (explicit rejection of Webster-type circumstantial evidence instruction)
- Jackson v. Virginia, 443 U.S. 307 (U.S.1979) (sufficiency standard: rational trier of fact could find elements beyond reasonable doubt)