State v. Coffelt, 1 CA-CR 16-0241

In March 2015 Deputy AD contacted Coffelt, who admitted selling methamphetamine from her home and consented to a search.
Deputy AD found ~17 grams of a white crystalline substance (tested positive for methamphetamine), cut straws and baggies with residue, razor blades, a small funnel, an electronic scale, glass pipes with burnt residue, and a bag of marijuana in a dresser drawer.
Coffelt admitted selling methamphetamine to address financial issues and acknowledged familiarity with distribution denominations; she claimed the marijuana belonged to a friend.
Coffelt was tried by jury and convicted of: (1) possession of methamphetamine for sale (class 2 felony); (2) possession of drug paraphernalia (class 6 felony); and (3) possession of marijuana (class 6 felony).
Sentence (mitigated, concurrent): five years for Count 1; six months each for Counts 2 and 3; fines imposed. A fourth count was dismissed before trial.
Counsel filed an Anders brief; Coffelt did not file a pro se supplemental brief. The Court reviewed the record for fundamental error and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for possession of methamphetamine for sale	Evidence (admission, 17g, packaging, scale, distribution familiarity) shows possession and intent to sell	Insufficiency argued implicitly via Anders brief (no meritorious issues raised)	Evidence sufficient; conviction affirmed
Possession of drug paraphernalia	Items (cut straws, pipes, scale, baggies, residue) and Coffelt's admission show intent/use as paraphernalia	Implicit challenge that items/possession insufficient to prove paraphernalia use	Evidence sufficient; conviction affirmed
Possession of marijuana	Marijuana found in dresser drawer constitutes possession (control/knowledge) despite Coffelt claiming it belonged to a friend	Claimed non-ownership and that she was merely holding it for someone else	Possession does not require ownership; evidence sufficient; conviction affirmed
Fundamental-error / Anders review	State: record contains no fundamental error; verdicts supported by evidence	Defense counsel raised no nonfrivolous issues; Coffelt filed no pro se brief	No fundamental error found; counsel relieved of further duties absent petition for review

Anders v. California, 386 U.S. 738 (1967) (procedural standards for appointed counsel to withdraw when appeal is frivolous)
Miranda v. Arizona, 384 U.S. 436 (1966) (requirement to advise suspects of rights before custodial interrogation)
State v. Henderson, 210 Ariz. 561 (2005) (standard for fundamental error review)
State v. Greene, 192 Ariz. 431 (1998) (reviewing sufficiency of evidence: view evidence in light most favorable to verdict)
State v. Soto-Fong, 187 Ariz. 186 (1996) (reversible error for insufficiency occurs only when no probative facts support conviction)
State v. Scott, 113 Ariz. 423 (1976) (same principle on evidentiary sufficiency)
State v. Cota, 191 Ariz. 380 (1998) (definition of possession requires control and knowledge)
State v. Shattuck, 140 Ariz. 582 (1984) (counsel's post-appeal obligations and defendant's options to seek review)