State v. Miles
Court of Appeals of South Carolina
805 S.E.2d 204 (2017)
Sheriff's agents suspected a FedEx package contained illegal drugs and conducted a controlled delivery to the address; Lance Miles (defendant) retrieved the package and admitted he knew it held drugs, though he claimed not to know which kind. The box actually contained over four grams of oxycodone, and Miles was charged with drug trafficking. During deliberations, the jury asked whether the State had to prove Miles knew the package held oxycodone specifically or just any illegal drugs; the judge instructed that the State only had to prove Miles knew the package contained illegal drugs generally, not the specific substance. Miles appealed his conviction on this instruction.
Whether drug-trafficking crimes require the accused to know he possessed an illegal drug, but not which specific illegal drug it was.