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In evaluating whether evidence is constitutionally sufficient to support a conviction, an appellate court must determine whether, viewing the evidence in the light most favorable to the prosecution, any rational trier of act could have found the defendant guilty beyond a reasonable doubt. However, the reviewing court may not disregard this duty simply because the record contains evidence that tends to support each fact necessary to constitute the crime. The reviewing court must consider the record as a whole since that is what a rational trier of fact would do.
Defendant Walter Booth, Jr., was charged by bill of information with possession of heroin, to which he pled not guilty. A twelve-person jury found him guilty as charged on February 19, 1998. Mr. Booth filed a motion for new trial that was set for hearing on the same day as his sentencing. However, the motion was not ruled on prior to Mr. Booth's sentencing on May 5, 1998, when he was sentenced to five years at hard labor. The trial court denied a motion to reconsider sentence, and granted a motion for appeal. Booth claimed that he was denied Brady material to which he was entitled, and that there was insufficient evidence presented to support his conviction.
Was Booth’s conviction supported by sufficient evidence?
The court found the evidence was sufficient for any rational trier of fact to find Booth knowingly exercised dominion and control over the heroin, and that all the essential elements of the possession offense were proven beyond a reasonable doubt.