United States v. Baggett
United States Court of Appeals for the Tenth Circuit
890 F.2d 1095 (1990)
Recorded phone calls showed Baggett (defendant) arranging to purchase heroin and cocaine from suspected dealer Daniels, and officers later observed a woman identified as Baggett meet briefly with Daniels twice, but neither officer saw any exchange of money or drugs, and no heroin was found on Baggett when she was arrested that day; a delayed confession to heroin use around the time of arrest was also introduced. The jury convicted Baggett, and she appealed.
Whether, when a defendant is charged with illegal drug possession and there is no direct evidence of guilt, there must be circumstantial evidence linking the defendant to an observed substance that the jury can infer to have been the drug.