805 S.E.2d 204
S.C. Ct. App.2017Background
- Federal Express package suspected of containing drugs was controlled-delivered to an apartment complex; Miles picked up the box and attempted to discard it when agents moved in, and was arrested.
- At arrest Miles initially told an agent he did not know the contents, then said the box "probably" contained drugs; agent read Miranda, asked again, and Miles again acknowledged the box could contain drugs.
- A search warrant and Miles' consent produced 300 pills totaling nine grams of oxycodone; Miles later wrote a statement admitting he was paid $100 to pick up the package and answered "Yes" to "Did you know drugs are in the parcel 'box'?" (other parts redacted).
- Miles was indicted under S.C. Code § 44-53-370(e)(3) for trafficking (4+ grams of a listed opioid), convicted by a jury, and sentenced to the mandatory minimum 25 years plus a $100,000 fine due to prior convictions.
- On appeal Miles argued (1) the trial court misinstructed the jury by saying the State did not have to prove he knew the drugs were oxycodone, (2) the denial of his directed verdict motion was erroneous, and (3) his statements should have been suppressed under Miranda/Seibert.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State must prove defendant knew the specific drug (oxycodone) to convict under § 44-53-370(e)(3) | Miles: "knowingly" modifies all elements; State must prove he knew the substance was oxycodone | State: "knowingly" applies to possession/related conduct, not to chemical identity; only knowledge of controlled nature required | Court: Affirmed; State need only prove defendant knew he possessed an illegal/controlled substance and prove quantity/type for sentencing/elemental proof, but not the defendant's awareness of chemical identity |
| Sufficiency of evidence / directed verdict | Miles: Insufficient evidence he knowingly trafficked oxycodone (no proof he knew it was oxycodone) | State: Possession, attempt to discard, admissions that box contained drugs, and the pills at his feet support inference of knowledge of contraband | Court: Affirmed denial; evidence (possession + admissions + circumstantial facts) was sufficient to go to the jury |
| Admissibility of statements under Miranda / Seibert (question-first tactic) | Miles: Initial questioning before Miranda and a later written statement rendered the written statement inadmissible under Seibert/Navy | State: First two statements were conceded at trial and the third was not objected on Seibert grounds below (unpreserved); alternatively, any error was harmless and the written statement was cumulative | Court: Issues regarding Seibert/Navy were unpreserved; even if considered, admission of the written statement was harmless and cumulative; conviction stands |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishing custodial interrogation warnings requirement)
- Flores-Figueroa v. United States, 556 U.S. 646 (statutory "knowingly" often applies to each element but is a contextual inquiry)
- McFadden v. United States, 135 S.Ct. 2298 ("knowingly" can apply to objects of verbs depending on context)
- United States v. Jones, 471 F.3d 535 (adverb "knowingly" modifies verb; not necessarily object)
- Staples v. United States, 511 U.S. 600 (different elements may require different mens rea)
- State v. Raffaldt, 318 S.C. 110 (amount, not criminal act, distinguishes trafficking from possession/distribution)
- State v. Taylor, 323 S.C. 162 (similar statutory language; knowledge of specific quantity/type not required for trafficking conviction)
- Missouri v. Seibert, 542 U.S. 600 ("question-first" Miranda violation doctrine)