Background

• Loggins was convicted in Union County Circuit Court of two counts of possession with intent to deliver, and additional counts including simultaneous possession of drugs and firearms, drug paraphernalia, and maintaining a drug premises; he was sentenced to life on the possession-and-firearms count and to lengthy consecutive terms plus fines.
• The defense challenged the sufficiency of the evidence to prove actual or constructive possession.
• The State argued constructive possession was proven by evidence Loggins exercised control or had dominion over contraband found in the home and nearby areas.
• The searches and seizures occurred at 1020 Craig Street, where drugs, firearms, paraphernalia, ledgers, and other items were found in plain view or accessible areas.
• Loggins testified he was only in the house to gamble and that he did not sell drugs there; testimony cited included a confidential informant’s purchases and a police raid.
• This court affirmed, holding substantial evidence supported constructive possession and maintaining the drug premises, and noting no prejudicial error in the proceedings.

Issues

Key Cases Cited

• Fernandez v. State, 362 S.W.3d 905 (Ark. 2010) (sufficiency of the evidence standard for directed-verdict review)
• Morgan v. State, 308 S.W.3d 147 (Ark. 2009) (circumstantial evidence must be consistent with guilt and exclusive of reasonable alternatives)
• Tubbs v. State, 257 S.W.3d 47 (Ark. 2007) (constructive possession may be inferred from proximity and control of contraband)
• Taylor v. State, 372 S.W.3d 769 (Ark. 2010) (accomplice testimony and need for corroboration when testimony is from a codefendant/accomplice)
• Carter v. State, 867 S.W.3d 544 (Ark. 2010) (joint premises case; related discussion of possession and evidentiary standards)