Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Evidence
Arrest, Search, and Investigation
State v. Sawyers, ___ N.C. App. ___, 808 S.E.2d 148 (Nov. 7, 2017)
In this possession of marijuana paraphernalia case, the State presented sufficient evidence to establish that the defendant constructively possessed a marijuana pipe found in a crashed vehicle. Although the defendant did not have exclusive possession of the vehicle, sufficient incriminating circumstances existed to establish constructive possession, including that the defendant was driving the vehicle; the pipe was found on the driver’s side floorboard; and the defendant admitted ownership of a small amount of marijuana found on his person.