Jayson Franklin Maxwell v. Commonwealth of Virginia.

Summary

The Supreme Court of Virginia held that the circumstantial evidence was insufficient as a matter of law to prove beyond a reasonable doubt that Jayson Franklin Maxwell constructively possessed crack cocaine and marijuana found in and under stacks of plywood behind a Farmville shopping center, because the proof did not exclude every reasonable hypothesis of innocence and mere proximity to the drugs cannot establish possession. Viewing the evidence in the light most favorable to the Commonwealth, the court concluded that no rational trier of fact could have found the essential elements of the offenses. It therefore reversed the en banc judgment of the Court of Appeals and dismissed both indictments. Justice Lemons, joined by Justice Kinser, dissented, contending that the combined force of the circumstances was sufficient to sustain the jury's verdict.