State v. M. McCoy, 498 P.3d 1266

McCoy (defendant) lived in Great Falls; L.B. (a minor, his step‑grandson/"Grandpa" relationship) frequently visited McCoy’s home in 2017–2018.
L.B. testified McCoy provided and smoked meth with him regularly (described pipe, "crystals," sharing/loading McCoy’s clear glass pipe).
Brown (L.B.’s mother and McCoy’s housemate) and Detective Lopez corroborated heavy drug use at McCoy’s house and that meth was commonly present; McCoy admitted he used meth but denied giving drugs to L.B.
No physical substance was recovered or laboratory‑tested; prosecution relied on L.B.’s testimony and corroborating witness accounts.
Jury convicted McCoy of Criminal Distribution of Dangerous Drugs and Endangering the Welfare of a Child; at sentencing, the court asked counsel whether McCoy wished to address the court, left timing to counsel, and later addressed McCoy personally; McCoy contended he was denied allocution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove McCoy distributed meth to L.B.	State: L.B.’s detailed testimony plus corroboration (Brown, Lopez, McCoy’s admissions about use and the house being a drug hub) suffices even without lab testing.	McCoy: Evidence insufficient because no substance was tested; only L.B. identified it as meth.	Affirmed — evidence sufficient: detailed, corroborated testimony and circumstantial proof allowed a rational juror to find distribution beyond a reasonable doubt.
Whether the court denied McCoy allocution at sentencing	State: Court asked if McCoy wished to speak and left timing to counsel; allocution effectively provided through counsel’s argument and defendant’s written statement; issue not preserved and harmless.	McCoy: Court failed to personally address him and deprived him of statutory and due process right to allocution; sentence should be vacated and resentenced by a new judge.	Affirmed — no statutory or constitutional violation: court inquired through counsel, afforded reasonable opportunity (including written defendant’s statement and counsel argument), and later addressed McCoy personally.

State v. Burwell, 313 P.3d 119 (holding that failure to submit a suspected substance for lab testing does not automatically make evidence insufficient when testimonial and circumstantial evidence supports identity)
State v. Dunn, 472 P.2d 288 (upholding conviction where victims’ detailed descriptions of drug effects corroborated identity despite no chemical analysis)
State v. Henrich, 886 P.2d 402 (reversing where victim’s unqualified opinion without corroboration was insufficient to identify meth)
State v. Hull, 487 P.2d 1314 (recognizing that direct testimonial proof of possession by a witness can sustain a conviction)
State v. Kaske, 47 P.3d 824 (holding testimony of a single witness may be sufficient and circumstantial evidence may prove elements)
State v. Webber, 448 P.3d 1091 (discussing due process rights at sentencing and the requirement to permit explanation/rebuttal of information that may affect deprivation of liberty)
Boardman v. Estelle, 957 F.2d 1523 (9th Cir.) (allocution construed as opportunity to present mitigating circumstances)
State v. McLeod, 61 P.3d 126 (discussing due process concerns where defendant lacked opportunity to contest sentencing foundations)