State of West Virginia v. Rodney A. Carpenter, 17-0117

Rodney A. Carpenter was indicted with others for operating or attempting to operate a clandestine methamphetamine laboratory and conspiracy after officers responded to a disturbance at Virginia Davis’s home on Aug. 6, 2015.
Deputies smelled chemicals (Coleman fuel), observed a bottle thrown from the back porch containing liquid and white granules, and obtained consent to search the property.
Photographs and recovered items included partially burned pseudoephedrine packaging, lithium batteries, cut bottles with filters, tubing, Coleman fuel, coffee filters, tin foil, a concealed "snort straw," and other paraphernalia commonly used in meth manufacture and use.
Forensic testimony indicated the manufacturing process was near completion when officers arrived. Some meth-lab components were hidden under the house and items were scattered as if being concealed quickly.
Co-defendant Billy Green testified he alone operated the lab outdoors and sought to exonerate Carpenter; the jury found Green not credible and convicted Carpenter on both counts.
Carpenter moved for judgment of acquittal post-trial arguing insufficient evidence (mere presence, no purchases or direct linkage); the trial court denied relief and sentenced Carpenter to concurrent prison terms; the Supreme Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict Carpenter of operating/attempting to operate a clandestine drug laboratory	State: evidence of active lab on premises, chemical smell, lab components inside house, items hidden and scattered — a rational jury could infer Carpenter participated	Carpenter: only present at scene; no direct link (no purchases, no items tied to him); Green admitted responsibility and said Carpenter was not involved	Affirmed: viewing evidence in prosecution’s favor, a reasonable juror could infer Carpenter associated with and assisted the operation (aiding/abetting or concerted action)
Sufficiency of evidence to convict Carpenter of conspiracy to operate/attempt to operate a clandestine lab	State: agreement can be inferred from words/actions/circumstances; overt acts existed (operation of lab) and presence with shared intent to share product	Carpenter: no evidence of any agreement, plan, or overt act by him beyond presence	Affirmed: jury could infer agreement from circumstantial evidence and shared conduct; conspiracy proven

State v. LaRock, 196 W.Va. 294, 470 S.E.2d 613 (W. Va. 1996) (standard for de novo review of sufficiency and viewing evidence in light most favorable to verdict)
State v. Guthrie, 194 W.Va. 657, 461 S.E.2d 163 (W. Va. 1995) (appellate review of sufficiency requires crediting inferences favorable to prosecution)
State v. Fortner, 182 W.Va. 345, 387 S.E.2d 812 (W. Va. 1989) (presence at scene is a factor; principles of aiding/abetting and concerted action)
State v. Less, 170 W.Va. 259, 294 S.E.2d 62 (W. Va. 1981) (agreement for conspiracy may be inferred from circumstantial evidence)