Leroy Washington v. State of Indiana (mem. dec.), 49A02-1707-CR-1665

On Sept. 21, 2016, Officer Rynard initiated a traffic stop of Leroy Washington after observing speeding and a hazardous turn; Washington fled when asked to exit his vehicle.
Officers pursued Washington a few blocks, stopped him, handcuffed him, and found $468 on his person.
A distinctive white-star backpack observed earlier in the passenger seat was missing from the car; Deputy Andre found it along the flight path.
The backpack emitted a marijuana odor and contained >46 grams of marijuana, a digital scale, empty baggies, a "skunk sack," and two broken jars with marijuana.
Washington was charged with resisting law enforcement, dealing in marijuana (Level 6 felony), and obstruction of justice; after a bench trial he was convicted on all counts and sentenced to 730 days in community corrections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State presented sufficient evidence of intent to deliver to support a Level 6 dealing in marijuana conviction	The State: possession of >30g plus scale, baggies, skunk sack, and cash permits a reasonable inference of intent to deliver	Washington: weight alone is insufficient after statutory amendment; the additional evidence here was "scant" compared to other cases	Affirmed — evidence (quantity, scale, baggies, skunk sack, varying cash denominations) was sufficient for an intent-to-deliver inference

Griffith v. State, 59 N.E.3d 947 (Ind. 2016) (standard for reviewing sufficiency of evidence on appeal)
McGuire v. State, 613 N.E.2d 861 (Ind. Ct. App. 1993) (circumstantial evidence such as scales, baggies, and quantities supports inference of intent to deliver)