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State v. Miles

Court of Appeals of South Carolina
805 S.E.2d 204 (2017)


Facts

Sheriff's agents suspected a FedEx package contained illegal drugs. They conducted a controlled delivery to the address listed and saw Lance Miles (defendant) retrieve it. Miles admitted there were drugs inside but did not know what kind. The prosecution charged him with drug trafficking because the box contained more than four grams of oxycodone. The judge instructed that the prosecution had to prove that Miles knowingly brought into the state, and knowingly possessed or attempted to possess, the oxycodone. The jury asked, “Does the [S]tate have to prove that the defendant knowingly brought into the state four grams or more of [o]xycodone or just any amount of illegal drugs in order to consider this trafficking?” The judge responded, “the State does not have to prove that the defendant knew that the drugs in the package were [o]xycodone, just that he knew that the package contained illegal drugs.” Miles appealed his conviction, arguing the prosecution had to prove he knew he possessed oxycodone.

Rule of Law

Issue

Holding and Reasoning (Hill, J.)

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