## Facts

- Sheriff’s agents in West Columbia, South Carolina, suspected a FedEx package contained illegal drugs.
- Agents arranged a controlled delivery to the address listed on the package, located in an apartment complex, and conducted surveillance.
- The FedEx driver rang the doorbell and left the package at the front door.
- A young woman came out from the delivery address, looked at the package, made a brief phone call, and went back inside.
- Lance Leon Miles exited a nearby apartment, walked around the parking lot, and used his phone while approaching the package.
- Miles picked up the package and began walking back toward his apartment.
- As agents advanced to intercept him, Miles attempted to discard the package.
- Agents detained and handcuffed Miles.
- Before Miranda warnings, an agent asked Miles what was in the package; Miles said he did not know. When asked if it contained drugs, Miles said there probably were drugs inside but he did not know what kind.
- After the agent administered Miranda warnings, Miles again stated the package could contain drugs, but he did not know what kind.
- Agents obtained authority to open the package and found 300 pills; a chemist later testified the pills contained a total of nine grams of oxycodone (more than four grams).
- After Miranda warnings were given again, Miles provided a written statement admitting he was paid $100 to pick up the box and answered “Yes” to a written question asking whether he knew drugs were in the parcel.
- The State charged Miles with trafficking in illegal drugs under S.C. Code Ann. § 44-53-370(e)(3) based on the oxycodone quantity.
- During deliberations, the jury asked whether the State had to prove Miles knowingly brought in and possessed four grams or more of oxycodone, or only that he knowingly possessed illegal drugs.
- Over defense objection, the trial judge instructed the jury that the State did not have to prove Miles knew the drugs were oxycodone, only that he knew the package contained illegal drugs, while still having to prove beyond a reasonable doubt that the drugs were more than four grams of oxycodone.
- The jury convicted Miles, and he appealed.

## Issues

1. Under S.C. Code Ann. § 44-53-370(e)(3), must the State prove the defendant knew the specific controlled substance was oxycodone (and thus met the four-gram threshold), or only that he knew he possessed illegal drugs?
2. Was the evidence sufficient to deny Miles’s directed verdict motion and submit the trafficking charge to the jury?
3. Did admission of Miles’s statements violate Miranda and the “question-first” principle (Missouri v. Seibert / State v. Navy), and if so, was any error preserved or prejudicial?

## Decision

- The South Carolina Court of Appeals affirmed Miles’s trafficking conviction and sentence.
- The court held the statute did not require proof that Miles knew the specific identity of the controlled substance (oxycodone); it was enough to prove he knew he possessed illegal drugs, while the State still had to prove the substance and quantity as objective facts.
- The court held the directed verdict motion was properly denied because there was evidence of possession, attempted disposal, and admissions supporting an inference that Miles knew the package contained illegal drugs, and the lab evidence proved the oxycodone weight.
- The court held the Seibert/Navy “question-first” challenge to the written statement was not preserved, and in any event any error was harmless because the written statement was cumulative and did not reasonably contribute to the verdict.

## Legal Principles

- For trafficking under S.C. Code Ann. § 44-53-370(e)(3), “knowingly” requires proof the defendant knew he was dealing with an illegal controlled substance; it does not require knowledge of the drug’s precise identity.
- The State must still prove beyond a reasonable doubt that the substance involved is the controlled substance charged and that it meets the statutory weight threshold triggering trafficking liability.
- Statutory interpretation in criminal cases focuses on legislative intent shown by text read in its statutory setting and purpose; a general presumption that “knowingly” applies to each element may yield where the statute’s structure indicates otherwise.
- The rule of lenity applies only when, after considering the statute in its setting, genuine ambiguity remains; it is not used to create ambiguity.
- Knowledge may be inferred from possession and surrounding circumstances; possession can support an inference that the possessor knows the character of the substance.
- Appellate review of evidentiary and constitutional claims requires preservation in the trial court; unraised theories are generally not reviewed on appeal.
- Even when an error is assumed, relief requires prejudice; admission of cumulative evidence may be harmless where it could not reasonably have affected the verdict.

## Conclusion

State v. Miles affirmed a trafficking conviction arising from a controlled-delivery interception of a FedEx package containing more than four grams of oxycodone, holding that § 44-53-370(e)(3) does not require the State to prove the defendant knew the drugs were specifically oxycodone, only that he knowingly possessed illegal drugs, and further holding the evidence was sufficient and any Miranda-related error concerning the written statement was unpreserved and harmless.


State v. Miles, 805 S.E.2d 204 (2017)