State v. Miles
805 S.E.2d 204 (2017)
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Rule of Law:
To secure a conviction for drug trafficking under S.C. Code Ann. § 44-53-370(e)(3), the State must prove the defendant knew they possessed a controlled substance, but it does not need to prove the defendant knew the specific identity of that substance.
Facts:
- Agents from the Lexington County Sheriff's Office identified a suspicious package at a Federal Express office and arranged a controlled delivery to an apartment complex.
- After the package was left at the delivery address, agents observed a young female emerge from that address, look at the box, and make a quick phone call before returning inside.
- Lance L. Miles, who had exited a nearby apartment, was then seen on his phone while walking toward the package.
- Miles picked up the package and began walking back toward his apartment.
- Upon seeing the agents advancing, Miles attempted to discard the box but was apprehended and handcuffed.
- A search of the box revealed three hundred pills, which were later confirmed to contain a total of nine grams of oxycodone.
- During questioning, Miles admitted he had been paid one hundred dollars to pick up the box for individuals named 'Mark' and 'Stacks'.
- In a written statement, Miles confirmed he knew there were drugs in the box.
Procedural Posture:
- Lance L. Miles was indicted for trafficking in illegal drugs in violation of section 44-53-370(e)(3).
- At trial in the state trial court, Miles' motion for a directed verdict was denied.
- During deliberations, the jury submitted a question to the trial court asking if the state had to prove Miles knew the drug was specifically oxycodone.
- Over Miles' objection, the trial judge instructed the jury that the state only had to prove Miles knew the package contained illegal drugs, not that he knew they were oxycodone.
- The jury returned a guilty verdict.
- Miles (appellant) appealed his conviction to the South Carolina Court of Appeals, arguing the trial court's supplemental jury instruction was erroneous.
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Issue:
Does the South Carolina drug trafficking statute, S.C. Code Ann. § 44-53-370(e)(3), require the State to prove that a defendant knew the specific identity of the controlled substance they possessed, or is it sufficient to prove the defendant knew they possessed an illegal drug?
Opinions:
Majority - Hill, J.
No. The South Carolina drug trafficking statute does not require the State to prove a defendant knew the specific identity of the controlled substance. The court reasoned that statutory interpretation must consider the text in its broader context and legislative purpose. By examining the entire statutory scheme (§ 44-53-370), the court concluded that the key distinction between simple possession and trafficking is the quantity of the drug, not a heightened mens rea as to the drug's specific type. The Legislature titled the offense 'trafficking in illegal drugs,' suggesting a general intent to criminalize dealing in any controlled substance above a certain weight. Requiring the State to prove knowledge of the specific chemical identity would create an absurdly high burden, effectively rewarding defendants for feigning ignorance of pharmacology and undermining the statute's purpose.
Analysis:
This decision establishes a key precedent in South Carolina by clarifying the mens rea requirement for drug trafficking, an issue the state's appellate courts had not previously addressed. By holding that knowledge of the specific drug type is not an element of the offense, the court significantly lowers the burden of proof for prosecutors. This ruling makes it easier to convict individuals, such as couriers, who may have credible deniability about the precise contents of a package but cannot deny knowing it contained contraband. The decision aligns South Carolina with the majority of jurisdictions on this issue and will likely strengthen the state's ability to prosecute large-scale drug trafficking operations.
