State v. Eafford
Annotate this CaseA jury found Defendant Donald Eafford guilty of permitting drug abuse and possession of cocaine. The court of appeals vacated Eafford's felony sentence for possession of cocaine and remanded for resentencing, holding that Eafford was convicted only of misdemeanor possession of drugs because the jury-verdict form did not state the degree of the offense or specify that Eafford had possessed cocaine. The Supreme Court reversed the court of appeals and reinstated the sentence, holding that the trial court did not plainly err in imposing sentence, as (1) the indictment charged Eafford with possession of cocaine, and the least degree of that offense is a felony of the fifth degree; (2) the evidence presented at trial proved Eafford possessed cocaine; (3) the trial court instructed the jury that it could find Eafford guilty only if it found the drug involved to be cocaine; and (4) the jury, which found Eafford guilty as charged in the indictment, thus found him guilty of possession of cocaine as a felony. .
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