Missouri v. Bell

Brief Fact Summary.

Tessie Bell, Defendant, an inmate at a correctional facility, claims that he did not have knowledge of a packet, which contained marijuana, content.

Synopsis of Rule of Law.

If the State solely offers into evidence proof that the Defendant had marijuana in his or her possession, then the jury may determine whether Defendant had knowledge of the marijuana in his possession.

Facts.

On October 21, 1984, David Andrews, a guard at the Missouri Training Center for Men at Moberly, a correctional institution searched the inmates, including Defendant. When searching Defendant, Andrews found a marijuana joint and a small packet containing marijuana in Defendant’s left rear pocket. Defendant claimed that he did not know the contents of the package because another inmate had given it to him to deliver to a third inmate.

Issue.

On October 21, 1984, David Andrews, a guard at the Missouri Training Center for Men at Moberly, a correctional institution searched the inmates, including Defendant. When searching Defendant, Andrews found a marijuana joint and a small packet containing marijuana in Defendant’s left rear pocket. Defendant claimed that he did not know the contents of the package because another inmate had given it to him to deliver to a third inmate.

Held.

Yes, the State offer uncontradicted evidence in which a jury could find that the Defendant had knowledge of the marijuana by showing that he was in possession of the packet containing it.

Dissent.

The majority is eliminating one of the three requisite elements that the State has the burden to prove with either direct or circumstantial evidence. Instead, the majority holds that the State solely has to make a showing of one element, possession, to create prima facia evidence for the element of knowledge.

Discussion.

Because there was not any direct evidence indicating that the Defendant had knowledge of the marijuana in his possession, other than his own testimony, the States showing of Defendants possession of the contents is sufficient. Therefore, a reasonable jury could conclude that Defendant had knowledge of the marijuana, as it was in his possession.