State v. Pigford

Pigford (defendant) was driving a commercial 18-wheeler through Louisiana when a weight-monitoring system on Interstate 20 registered that the truck was 3,000 pounds over the state’s legal weight limit. At a weigh station, officers confirmed the weight of the truck. Pigford told the officers that he was going to New York. This conflicted with the truck’s bill of lading, which stated that the truck was hauling grapes from California to Pennsylvania. The officers, concerned about the discrepancy in Pigford’s destination and his seemingly off-route trip along Interstate 20, asked to see inside the truck’s cargo area. Pigford refused. After an agent of the Public Service Commission arrived, Pigford relented and opened the cargo area. The officers discovered a package, set on top of the grapes and not visible from the ground, that contained 52 pounds of marijuana. The cargo otherwise corresponded with the bill of lading. Although Pigford claimed he did not know anything about the package, he was convicted of possession of marijuana with intent to distribute under Louisiana Revised Statutes § 40:966(A)(1). At trial, Pigford argued that: (1) he was on route, because Interstate 20 did connect with California, and (2) it was possible someone loaded the marijuana on the truck without his knowledge and was going to have it removed at the truck’s final destination also without his knowledge. The Louisiana Second Circuit Court of Appeal reversed the conviction on the ground that the prosecution’s evidence did not sufficiently demonstrate constructive possession of the marijuana. The state appealed.