State of Iowa v. Randy Crawford
16-0771
| Iowa Ct. App. | Dec 21, 2016Background
- 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)
