STATE OF FLORIDA v. ALEXANDER LEE
230 So. 3d 886
| Fla. Dist. Ct. App. | 2017Background
- Police stopped Lee after he parked at a house; a man briefly entered the passenger side and then left.
- Officers searched the vehicle and found a small rock of crack cocaine on the sliding track under the driver’s seat.
- The car’s registration was linked to Lee, but there was no evidence whether he owned the car or whether others regularly used it.
- A jury convicted Lee of possession of cocaine; the trial court nonetheless granted Lee’s motion for judgment of acquittal.
- Trial court reasoned there was no evidence Lee knew about or exercised control over the drug, likening criminal liability to searching every vehicle crevice.
- The State appealed the judgment of acquittal; the Fourth District reviews de novo whether evidence, viewed in the light most favorable to the State, established a prima facie case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence sufficed to deny judgment of acquittal on constructive possession of cocaine found in vehicle | State: Lee’s exclusive possession and control of the vehicle (registration linked to him) supports an inference of knowledge and control, establishing a prima facie case | Lee: No direct evidence he knew of or handled the drug; brief presence of another person undermines constructive-possession inference | Reversed trial court; jury verdict reinstated — exclusive control of vehicle supported unrebutted inference of constructive possession and prima facie guilt |
Key Cases Cited
- State v. Rincon, 700 So. 2d 412 (Fla. 1997) (explains appellate review of judgments of acquittal and double jeopardy implications)
- State v. Konegen, 18 So. 3d 697 (Fla. 4th DCA 2009) (standard of review for sufficiency on judgment of acquittal)
- State v. Odom, 862 So. 2d 56 (Fla. 2d DCA 2003) (defendant admits facts and reasonable inferences favoring the State on motion for judgment of acquittal)
- Ubiles v. State, 23 So. 3d 1288 (Fla. 4th DCA 2010) (elements of constructive possession: knowledge and control)
- Lee v. State, 835 So. 2d 1177 (Fla. 4th DCA 2002) (exclusive control of vehicle supports rebuttable inference of knowledge of contraband)
- State v. Herron, 70 So. 3d 705 (Fla. 4th DCA 2011) (reversal of judgment of acquittal where jury reasonably could find elements satisfied)