State v. Campbell, 171 So. 3d 1176

Campbell was convicted of possession with intent to distribute cocaine in violation of La. R.S. 40:967(A)(1).
Officers executed a search warrant at 1438 Joliet Street/8502 Jeannette Street, a shared parcel; a shed contained cocaine and related items.
Cocaine was found in plain view on a dresser in the shed; Campbell stood near the dresser when discovered.
Paraphernalia linking to drug packaging and absence of personal-use paraphernalia were recovered nearby.
State presented a post-arrest rebuttal about a prior controlled buy; defense objected and trial judge allowed the rebuttal evidence.
Court affirmed Campbell’s conviction and held the rebuttal evidence was harmless error despite the ruling on door-opening.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for possession and intent	Campbell argues no possession or intent established	N/A	Sufficient evidence supported both elements
Admissibility of rebuttal evidence of the pre-warrant controlled purchase	State may rebut defense denial of drug dealing	State opened the door; admission was error	Rebuttal evidence admitted but error harmless

State v. Brown, 907 So.2d 1 (La. 2005) (standard for sufficiency of evidence; Jackson v. Virginia applied)
State v. Neal, 796 So.2d 649 (La. 2001) (sufficiency, circumstantial evidence rules)
State v. Captville, 448 So.2d 676 (La. 1984) (considers standard for sufficiency and burden of proof)
State v. Rosiere, 488 So.2d 965 (La. 1986) (circumstantial evidence standard in guilt determination)
State v. House, 325 So.2d 222 (La. 1975) (five factors for intent to distribute analysis)
State v. Francois, 844 So.2d 1042 (La. App. 4 Cir. 2003) (packaging as indicator of distribution; foreseeability of personal use vs. distribution)
State v. Hearold, 603 So.2d 731 (La. 1992) (House factors for distribution intent (footnote tradition))