Folk v. Maryland

275 A.2d 184, 11 Md. App. 508 (1971)

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Folk v. Maryland

Maryland Court of Appeals
275 A.2d 184, 11 Md. App. 508 (1971)

Facts

Lillie Mae Folk (defendant) was with five other people in a car parked on an abandoned, overgrown baseball field in a remote area. Earlier that evening, the driver of the car had retrieved a roll of paper towels from the car’s trunk. A police officer surveilling the car saw one of the occupants in the back seat light a cigarette and pass it to another occupant sitting in the front seat. The officer then approached the car, which had its windows rolled up, and smelled marijuana smoke when the driver’s side front window was rolled down. The officer ordered the occupants to exit the car. When they did, a male passenger who exited from the passenger side threw a black box containing marijuana into the field. All of the car’s occupants were arrested. Folk did not explain why she was in a car parked on a remote baseball field and was convicted of unlawful possession of marijuana. Folk appealed, arguing that the evidence was insufficient to prove that Folk possessed the marijuana beyond a reasonable doubt.

Rule of Law

Issue

Holding and Reasoning (Moylan, J.)

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