State v. Suddit

379 Md. 425, 842 A.2d 716 (2004)

Facts

An officer observed a Ford Explorer being driven with its headlights off and he attempted to stop the vehicle. It fled the scene and a high-speed pursuit by the police ensued. The Explorer matched the description of a vehicle that recently had been carjacked and reported stolen. The driver of the Explorer lost control of the vehicle, and it flipped over three times before stopping. The four occupants were arrested for the theft of the Explorer. On a search incident to the arrest, a lot of drugs and drug paraphernalia were found strewn throughout the car. No drugs were found on D’s person. At trial, D moved for a judgment of acquittal because P did not meet its “burden of proof beyond a reasonable doubt” that D knew of or possessed the contraband. The trial court refused, and D was found respondent guilty on the charges of possession of heroin, possession of cocaine and possession of drug paraphernalia. D appealed, and the conviction was reversed. The evidence was insufficient to support the inferences that respondent either exercised control over the contraband or knew that the contraband was in the vehicle. P appealed.