Robert E. Dyas v. State of Arkansas, 593 S.W.3d 55

Robert E. Dyas was convicted in Jefferson County for possession of methamphetamine and sentenced to six years.
Police stopped Dyas, discovered outstanding warrants, arrested him, and called for a tow; an inventory search of the vehicle followed.
Officers found a black bag with methamphetamine and a pipe inside a small ice chest on the front passenger floorboard; Dyas was the sole occupant.
Officer Hoffman testified the ice chest was visible and reachable from the driver’s seat and that Dyas admitted the drugs were his; laboratory testing confirmed methamphetamine.
On appeal Dyas argued insufficient evidence of actual or constructive possession, challenging ownership of the car, lack of photos/bodycam, no fingerprinting, and questioning Hoffman’s credibility for not documenting the admission or giving Miranda warnings.
The trial court acquitted Dyas of paraphernalia; the Court of Appeals reviewed the sufficiency claim under the substantial-evidence/constructive-possession standards and affirmed.

Issue	Dyas's Argument	State's Argument	Held
Sufficiency—constructive possession of methamphetamine	Items in car could belong to others; police failed to investigate car ownership, preserve photos/bodycam, or collect fingerprints; officer’s unrecorded admission is unreliable	Single-occupant vehicle, contraband located in place immediately and exclusively accessible to Dyas, officer testimony (including admission), lab confirmation	Affirmed. Constructive possession supported by substantial evidence: drugs were reachable from driver’s seat and subject to Dyas’s control; credibility for jury to decide

Foster v. State, 467 S.W.3d 176 (Ark. App. 2015) (defines substantial-evidence standard and explains constructive-possession principles)
Polk v. State, 73 S.W.3d 609 (Ark. 2002) (witness credibility is for the fact-finder)