Tatum v. State, 2011 Ark. App. 83

Appellant Mario Tatum was convicted by a jury of possession of cocaine and possession of marijuana (second offense).
Sentences were six years for cocaine and five years for marijuana; sentences run concurrently depending on jurisdiction, as indicated in the opinion.
Appellant appeals asserting insufficiency of the evidence and flaws in the chain of custody for the controlled substances.
Corporal Larry McMahon testified he submitted evidence to the crime lab on December 17, 2009; he recognizable submission sheet and his name appeared on it.
Trooper Dixon testified he observed a stop, saw something thrown from the vehicle, and recovered bags later found to contain marijuana and cocaine; he transported contraband to the evidence vault.
The State sought to admit the marijuana and cocaine over a chain-of-custody challenge; the court admitted the exhibits, noting packaging tapes and seals; Appellant testified denying possession or throwing anything.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence of possession?	Tatum argues video doesn’t show door opening and no drugs were found on him, passenger, or in vehicle.	State contends testimony of stop and retrieval of drugs supports possession conviction.	Yes; evidence viewed in the State's favor supports conviction.
Was the chain of custody properly established?	McLemore’s absence to testify about the package’s condition undermines authenticity.	Trial court properly assessed authenticity; not every contact person must testify; lack of one witness does not require reversal.	No abuse of discretion; chain of custody sufficiently established to admit the evidence.

Moms v. State, 2011 Ark. App. 12 (Ark. App. 2011) (directed-verdict standard tied to sufficiency; evidence viewed in the light favorable to verdict)
Jackson v. State, 374 S.W.3d 857 (Ark. Supreme Court 2010) (chain-of-custody authenticity; not all contacts must be traced to admit evidence)