Knight v. State
Annotate this CaseDefendant was charged with possession with intent to sell or deliver and possession of more than twenty grams of cannabis. Defendant appealed, arguing that the trial court erred in refusing to grant his motion for judgment of acquittal. Recognizing that Defendant was convicted under a theory of constructive possession, the court of appeal affirmed Defendant’s conviction, finding that the circumstantial evidence standard should apply only where both elements of constructive possession are proven solely by circumstantial evidence. The Supreme Court approved the court of appeal’s decision and upheld Defendant’s conviction for constructive possession, holding (1) the circumstantial evidence standard of review continues to apply in Florida; (2) with direct evidence of dominion and control, Defendant’s case could not be considered wholly circumstantial, and therefore, the circumstantial evidence standard of review does not apply; and (3) the State produced sufficient evidence that a rational jury could find the elements of the crime beyond a reasonable doubt.
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