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United States v. Stanley | 24 F.3d 1314 (1994)
You can’t be convicted of a crime unless the evidence against you meets the required standard of proof. The Eleventh Circuit considered whether there was sufficient evidence to sustain a defendant’s drug conviction in the Nineteen Ninety-Four case United States versus Stanley.
Charles Reynaldo Cameron, Tiffany Sherrell Stanley, and Ronald Calvin Powers were prosecuted in federal d istrict court for possession with intent to distribute cocaine base in violation of the Controlled Substances Act. Powers was tried separately and convicted.
At Cameron’s and Stanley’s trial, the evidence established that accused cocaine trafficker Timothy Wayne Murray agreed to help the police catch his suppliers in Atlanta, Georgia. To that end, Murray called Cameron to arrange a drug deal. During the course of their conversation, Cameron agreed to drive down to Columbus, Georgia, that night with three and a half ounces of cocaine base, and Murray agreed to pay thirty-six hundred dollars in exchange.
Several hours later, Cameron called Murray from a prearranged location in Columbus, and an undercover police officer drove Murray there in an old pick-up truck. As Murray approached Cameron’s car, he saw two passengers, Stanley and Powers. Murray asked Cameron where the dope was, and Powers said that Murray needed to talk to him. When Murray and Powers were done talking, Murray ostensibly went to get the money for the drug deal.
Meanwhile, police officers moved in to make the arrests. They searched Cameron’s car and discovered plastic bags filled with a substance that looked like cocaine base hidden under the dashboard. Cameron admitted that the bags were his but claimed that the substance was baking powder. Later that night, the police officers weighed the substance on scales in the police department; it weighed one hundred five point six grams. The state crime lab subsequently determined that the substance was cocaine base and that it weighed eighty-eight grams.
The jury convicted both Cameron and Stanley, who appealed to the Eleventh Circuit. The court ultimately vacated Stanley’s conviction on the basis that her mere presence in the car was insufficient evidence of guilt. Turning to Cameron’s appeal, Cameron alleged that the evidence against him was insufficient because the government failed to prove that the cocaine base identified at trial was the same as the substance discovered in his car on the night of his arrest. To support this allegation, Cameron relied on the fact that the substances were weighed twice and the weights didn’t match.
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