Law School Case Brief
State v. Miles - 421 S.C. 154, 805 S.E.2d 204 (Ct. App. 2017)
Because S.C. Code Ann. § 44-53-370(c) only requires knowledge that the substance is "controlled," and because the only difference between the elements of distribution and simple possession and the elements of trafficking is the amount of the controlled substance involved, there is no reason to suspect the South Carolina Legislature meant to require knowledge of the specific type of controlled substance in trafficking prosecutions.
While scanning parcels for illegal drugs at the Federal Express office, agents from the Lexington County Sheriff's Office became suspicious of a package. They arranged for a controlled delivery to the listed address, which was within an apartment complex. Surveilling the delivery, they observed the delivery person ring the doorbell and leave the package by the front door. A few moments later, an agent noticed defendant Miles exit a nearby apartment and begin walking around the parking lot. The agent then saw a young female emerge from the delivery address. She looked at the box, got on her phone, quickly hung up and went back inside. Miles then got on his phone while walking towards the box. Miles picked up the box and started back to his apartment. Seeing the agents advancing to intercept him, he tried to ditch the box. The agents apprehended and handcuffed him. Agent Edmonson immediately questioned Miles about the contents of the box. Miles claimed he did not know what was inside. Edmonson then asked if there were drugs inside the box; Miles responded there probably were, but he did not know what kind. At this point, Edmonson read Miles his Miranda rights and asked Miles again whether there were drugs in the box. Miles again responded the box could contain drugs, but he did not know what kind. Upon obtaining a search warrant and Miles' consent, the agents opened the box and discovered 300 pills that a chemist later testified contained a total of nine grams of oxycodone. Miles was convicted for trafficking in illegal drugs. On appeal, he argued that the trial court erred by: (1) instructing the jury, in reply to a question they posed during deliberation, that the State did not have to prove Miles knew the drugs were oxycodone; (2) denying his directed verdict motion; and (3) admitting three statements he contends were obtained in violation of his Miranda rights. Miles' primary argument on appeal was that the trial court's supplemental charge misinformed the jury that the State did not need to prove beyond a reasonable doubt that Miles knew the drug he possessed was oxycodone.
Did the trial court err in instructing the jury, in reply to a question they posed during deliberation, that the State did not have to prove defendant knew the drugs in a parcel were oxycodone?
The Court of Appeals of South Carolina affirmed the conviction. The Court found that by using "knowingly" in the statute, the Legislature did not intend to require the State to prove a defendant knew the specific type of illegal drug he was trafficking. The Court held that the trial court did not err in instructing the jury, in reply to a question they posed during deliberation. The State did not have to prove defendant knew the drugs were oxycodone because the instructions conveyed the pertinent legal standards to the jury and correctly charged that the State still bore the burden of proving the drug quantity and identity. The Court also rejected defendant's argument that he was entitled to a directed verdict because there was ample direct and substantial circumstantial evidence from which defendant's guilt could be fairly and logically deduced, including defendant's possession of the box containing the drugs and his written admission he knew drugs were in the box.
As for the applicable standard of review, the Court explained that it reviews jury instructions to determine whether they, as a whole, adequately communicate the law in light of the issues and evidence presented at trial. The Court was also mindful that statutory interpretation begins (and often ends) with the text of the statute in question. Absent an ambiguity, there is nothing for a court to construe, that is, a court should not look beyond the statutory text to discern its meaning. The Court's duty is to determine legislative intent, and the text of the statute is often the best evidence of that intent. Yet the text must be construed in context and in light of the intended purpose of the statute in a manner which harmonizes with its subject matter and accords with its general purpose.
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