Louisiana v. Hughes
Annotate this CaseDefendant Brian Hughes was arrested in the parking lot of Grant Junior High School, near Dry Prong, Louisiana. A search incident to arrest revealed a plastic bag in defendant’s pocket, which contained a substance that appeared to be crystal methamphetamine. The Grant Parish Sheriff’s office determined that the substance weighed 2.3 grams. The substance was sent to the North Louisiana Crime Lab for chemical testing. The Crime Lab determined it was methamphetamine. At the Crime Lab, however, the methamphetamine weighed 1.73 grams. Defendant was found guilty as charged of possession of methamphetamine, La.R.S. 40:967 (which at the time of the crime did not differentiate the offense into grades by weights less than 28 grams), and sentenced to five years imprisonment at hard labor. The court of appeal reversed the conviction because it found the evidence insufficient to support it. Specifically, the court of appeal found “that the weight discrepancy of the substance measured by the Grant Parish Sheriff’s Department (2.3 grams) and the weight recorded by the analyst at the Crime Lab (1.73 grams) provided reasonable doubt as to whether the lab received and analyzed the same evidence taken from Defendant’s pocket.” The Louisiana Supreme Court determined the state established the chain of custody at trial, and the jury could reasonably conclude that the substance seized from the defendant was the substance tested by the crime lab and introduced as evidence at trial, the discrepancy in the weights notwithstanding. Accordingly, the Supreme Court reversed the court of appeal’s decision, and reinstated the conviction and sentence, which were affirmed.
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