State v. Pigford

Summary

The Supreme Court of Louisiana reinstated Pigford's conviction for possession of marijuana with intent to distribute and his eight-year hard labor sentence, vacating the Second Circuit's contrary sufficiency ruling. The per curiam held that the jury acted reasonably in rejecting Pigford's hypothesis of innocence — that unknown third parties stashed roughly 52 pounds of marijuana atop his grape load without his knowledge — and that the court of appeal erred by substituting its own appreciation of the evidence for that of the fact-finder. Although a commercial driver's access to an unsealed cargo area alone does not establish guilty knowledge, the Court found guilty knowledge could rationally be inferred from Pigford's nervousness, his circuitous route and false statements about his destination, the accessible placement of the package, and the quantity and value of the contraband. The case was remanded to the court of appeal for the remaining pretermitted assignments of error.