State v. Pigford
Supreme Court of Louisiana
922 So. 2d 517 (2006)
A weight-monitoring system flagged Pigford's (defendant) commercial truck as overweight; at the weigh station, his stated destination conflicted with the truck's bill of lading, and after initially refusing to let officers inspect the cargo, he eventually relented and officers found 52 pounds of marijuana hidden atop the grapes, in a padlocked (not shipper-sealed) cargo area, not visible from ground level. Pigford was convicted of possession with intent to distribute despite claiming he had no knowledge of the drugs and that someone else could have loaded them without his awareness. The court of appeal reversed for insufficient evidence of constructive possession, and the State appealed.
Whether, for purposes of establishing constructive possession, dominion and control over a substance can be inferred from the surrounding circumstances.