United States v. Stanley
United States Court of Appeals for the Eleventh Circuit
24 F.3d 1314 (1994)
The government (plaintiff) prosecuted Tiffany Stanley, Ronald Powers, and Charles Cameron (defendants) for possession with intent to distribute cocaine base after a sting operation led to their arrest and the seizure of drug-filled bags from Cameron's car, which Cameron admitted were his. Officers initially weighed the bags at 105.6 ounces using a poorly maintained scale borrowed from a drug dealer, but the state crime lab's later re-analysis measured only 88 grams. The government presented chain-of-custody testimony linking the seized substance to the substance tested at trial, along with testimony explaining the earlier reading was a false one caused by the faulty scale. The jury convicted Cameron, who appealed, challenging the sufficiency of the evidence given the weight discrepancy.
Whether a conviction for possession with intent to distribute a controlled substance requires proof that the substance identified at trial is the same as the substance seized at the time of arrest.