History
  • No items yet
midpage
State of Iowa v. Randy Crawford
16-0771
| Iowa Ct. App. | Dec 21, 2016
Read the full case

Background

  • On Nov. 1, 2015, an officer saw a small knotted plastic bag fall from a passing car; Randy Crawford (rear passenger) exited, retrieved the bag from a crosswalk, and attempted to flee.
  • The officer chased Crawford; Crawford tripped when his pants fell, the bag dropped, and it was recovered containing a few grams of marijuana.
  • Crawford was charged with possession of marijuana (first offense) under Iowa Code §124.401(5). His motions for judgment of acquittal were denied; a jury convicted him.
  • On appeal Crawford challenged the sufficiency of the evidence, arguing lack of actual possession and lack of knowledge that the bag contained marijuana (treating it like a constructive-possession claim).
  • The court reviewed the record in the light most favorable to the State to determine whether substantial evidence supported the conviction.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence for possession Evidence showed Crawford picked up the bag and tried to flee with it, demonstrating dominion and control and knowledge Crawford argued evidence only established constructive possession or was insufficient to show he knew it was marijuana Affirmed — jury could find actual possession and knowledge beyond a reasonable doubt

Key Cases Cited

  • State v. Alvarado, 875 N.W.2d 713 (Iowa 2016) (standard of review for sufficiency of the evidence)
  • State v. Howse, 875 N.W.2d 684 (Iowa 2016) (definition of substantial evidence standard)
  • State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (elements required to prove possession: dominion/control and knowledge)
  • State v. Nitcher, 720 N.W.2d 547 (Iowa 2006) (jury assesses witness credibility)
  • State v. Thornton, 498 N.W.2d 670 (Iowa 1993) (jury authority to accept or reject testimony)
  • State v. Blair, 347 N.W.2d 416 (Iowa 1984) (role of jury in weighing evidence and credibility)
  • State v. Musser, 721 N.W.2d 758 (Iowa 2006) (court should not resolve credibility or weigh evidence)
Read the full case

Case Details

Case Name: State of Iowa v. Randy Crawford
Court Name: Court of Appeals of Iowa
Date Published: Dec 21, 2016
Docket Number: 16-0771
Court Abbreviation: Iowa Ct. App.