## Facts

- A commercial weight-monitoring system detected an eastbound Volvo 18-wheel truck driven by Richard Thomas Pigford as approximately 3,000 pounds overweight on Interstate 20 in Caddo Parish, Louisiana, and officers directed the truck to a weigh station.
- Pigford told officers he was traveling to New York, but the bill of lading listed a shipment of grapes from Reedley, California, to Pittsburgh, Pennsylvania.
- Officers requested access to the trailer based on the destination discrepancy and perceived irregular route; Pigford refused, asserting a right to refuse a search.
- After a Louisiana Public Service Commission agent arrived and advised that the trailer could be placed out of service if not opened, Pigford produced the only key and opened the padlocked trailer; the shipper had not sealed the trailer.
- Officers found grapes consistent with the bill of lading and a package placed on top of the grapes containing about 52 pounds of marijuana valued at roughly $50,000.
- Pigford was charged with possession of marijuana with intent to distribute; he represented himself at trial until he fled during a recess after the State rested, and the trial proceeded in absentia to a guilty verdict.
- The trial court later sentenced Pigford to eight years at hard labor; the court of appeal reversed for insufficient evidence of constructive possession; the state high court granted review.

## Issues

1. Whether, viewing the evidence in the light most favorable to the prosecution, a rational juror could find beyond a reasonable doubt that Pigford constructively possessed the marijuana and had guilty knowledge.
2. Whether the intermediate appellate court exceeded the proper limits of sufficiency review by substituting its own view of the evidence for the jury’s and crediting a defense hypothesis of innocence rejected at trial.

## Decision

- The court reversed the judgment of the court of appeal.
- The court held the evidence was sufficient for a rational jury to find constructive possession and guilty knowledge.
- The court reinstated Pigford’s conviction and eight-year sentence.
- The court remanded for consideration of other assignments of error not previously reached.

## Legal Principles

- On sufficiency review, the question is whether any rational trier of fact, viewing the evidence in the light most favorable to the prosecution, could find each element beyond a reasonable doubt; appellate courts may not reweigh evidence or reassess credibility.
- Constructive possession may be proved by circumstantial evidence showing dominion and control over the place where contraband is found, together with facts supporting guilty knowledge.
- A reviewing court may not reverse by reviving a defendant’s hypothesis of innocence when a rational jury could reject that hypothesis based on the totality of circumstantial evidence.
- In evaluating knowledge, jurors may consider practical inferences from the circumstances, including exclusive access to a locked container, discrepancies in travel explanations, placement of contraband among cargo, and the improbability that valuable contraband would be entrusted to an unwitting carrier.

## Conclusion

The court reinstated the conviction because the jury could rationally infer constructive possession and knowledge from Pigford’s exclusive access to an unsealed, padlocked trailer, the destination discrepancy and surrounding circumstances, and the placement and value of the marijuana, and because the court of appeal improperly displaced the jury’s factual inferences under the governing sufficiency standard.


State v. Pigford, 922 So. 2d 517 (La. 2006)