Garcia v. Florida

After stopping Garcia (defendant) for erratic driving and arresting him for DUI, deputies searching his car incident to arrest found a taped bundle under the passenger seat containing methamphetamine mixed with a cutting agent; Garcia claimed he didn't know the package was in the car, noting others had access to the vehicle, which had recently been stolen and returned. Garcia was convicted of the lesser-included offense of methamphetamine possession, and though the trial court instructed the jury that knowledge of the substance's identity was required for the greater trafficking charge, its instruction on the lesser possession offense didn't expressly repeat that knowledge requirement; the district court agreed this was error but found it unpreserved and non-fundamental, certifying the conflict to the Florida Supreme Court.