Facts
During a lawful traffic stop for various vehicle infractions (a missing license plate, broken brake light, etc.) and “suspicious” driving behavior, officers discovered that the driver, Mr. True Sparling, had a suspended driver license and the passenger’s license was also expired, leading to the decision to impound the vehicle. While performing an inventory search of the vehicle officers discovered a “crystallized pink rock” identified as methamphetamine, a “black tar substance” identified as heroin, and Sparling’s broken-in-half driver license all within Passenger’s purse that was found on the passenger-side front seat.
Sparling denied any knowledge or ownership of the drugs and Passenger initially claimed sole ownership of them. Upon further questioning Passenger stated and affirmed that Sparling and Passenger had used the meth together the prior day, using Sparling’s broken-in-half license to chop up the methamphetamine.
Analysis
At trial the district court reasoned that Sparling had constructive possession of the meth found in Passenger’s purse, indicating that he knew of the substance as well as intended to possess, use, or control it, despite the meth not being found on his person. This led to a conviction for methamphetamine possession. The court relied on several pieces of evidence to connect Sparling with the meth, including Sparling’s evasive driving pattern prior to the stop, Sparling’s broken license found within the purse, and Passenger’s statements regarding using the meth with Sparling. The prosecution had also introduced evidence showing that Sparling regularly sent messages from Passenger’s phone in order to sell the meth that they had acquired together. Sparling appealed his conviction on the grounds that there was insufficient evidence to connect him with the drugs.
Ruling
The Court of Appeals reviewed Sparling’s conviction for clear error as to whether the State had “presented sufficient evidence to support Sparling’s conviction.” The Court reasoned that Sparling met several of the needed standards to reach constructive possession, including Sparling’s occupancy of the vehicle, proximity to the meth, previous drug use, and suspicious driving behavior prior to the stop. Sparling clearly had knowledge of the drug as he had driven Passenger in order to make the purchase and had used the drug the prior day.
The Court reasoned that Sparling had not only a history of prior drug use, but had actually used “the very drugs in question” in this case. Sparling’s connection extended beyond mere knowledge of the meth, but included his intent to use and sell the drug to others as well, given his text messages to potential customers. The Court of Appeals ruled that the totality of evidence was sufficient to support Sparling’s conviction for possession of methamphetamine and affirmed the conviction.