State v. Martin, 2017 SD 65

On Sept. 15, 2015, police arrested Christopher Martin on an outstanding warrant after locating an abandoned vehicle he had reported stolen; a search incident to arrest revealed 23 pills in his pocket that appeared to be oxycodone, wrapped in cellophane, and a large quantity of cash.
Martin initially said the pills belonged to "a friend or friends," later told police they belonged to a woman named Jessica but gave inconsistent accounts about how the pills got into his vehicle.
Detective Ganser located Jessica, who acknowledged keeping prescription oxycodone in her home, had given Martin a key, had seen him in her home, and had been away in Utah shortly before Martin’s arrest; she denied giving or selling pills to Martin.
Pills in Martin’s pocket resembled the pills in Jessica’s prescription bottle; Jessica stored pills disorganizedly and had been on probation for attempting to obtain more oxycodone.
Martin moved for judgments of acquittal at the close of the State’s case and after verdict; both motions were denied. He conceded possession but argued the State failed to prove he knowingly possessed oxycodone (a controlled substance).
The circuit court convicted Martin of unlawful possession of a controlled substance; on appeal the Supreme Court of South Dakota reviewed whether the evidence was sufficient to show Martin knew the pills were a controlled substance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was sufficient to prove Martin knowingly possessed a controlled substance (oxycodone)	Circumstantial evidence (pills wrapped with cash, similarity to Jessica’s pills, Martin’s access to Jessica’s home, inconsistent/false statements) supported an inference Martin knew the pills were controlled	Martin conceded possession but argued he did not know the pills were oxycodone or a controlled substance — the State presented no direct proof of that knowledge	Affirmed. Viewing evidence in the light most favorable to the State, a rational jury could infer Martin knew the pills were a controlled substance

McFadden v. United States, 135 S. Ct. 2298 (2015) ("knowingly" applies to the object of possession requirement for controlled substances)
United States v. Martin, 274 F.3d 1208 (8th Cir. 2001) (defendant need only know he possessed some controlled substance, not its exact identity)
United States v. De La Torre, 599 F.3d 1198 (10th Cir. 2010) (mens rea for possession can be proven via knowledge that substance is a controlled drug)
United States v. Abdulle, 564 F.3d 119 (2d Cir. 2009) (government need not prove defendant knew exact nature of drug; only that it was a controlled substance)
United States v. Carranza, 289 F.3d 634 (9th Cir. 2002) (conviction may rest on belief that one possesses a controlled substance)