State v. Smith

Summary

The Supreme Court of Louisiana reversed the court of appeal and reinstated the trial court's denial of Heather Smith's motion to quash charges for second-degree murder and possession of MDMA with intent to distribute. The court held that the allegations could support a finding that Smith acted as an intermediary by obtaining drugs from a source and transferring them to other members of a joint venture, potentially establishing distribution and the requisite intent.

Holdings

1. The allegations were sufficient to support a charge that Smith acted as an intermediary and principal in the distribution of MDMA. A person who obtains a controlled substance from a source and then transfers it to other users may be a link in the chain of distribution even if she also intended to use some of the drug herself.
2. The trial court properly denied the motion to quash because the State's allegations could conceivably establish distribution and intent to distribute; the factual issues were for the factfinder at trial.

Questions Presented

1. Whether the State's allegations that Smith obtained MDMA from a source and then brought and divided it among members of the joint venture were sufficient to charge her as a principal in the distribution of a controlled substance.
2. Whether the State's allegations were legally insufficient on a pretrial motion to quash because Smith was allegedly only a purchaser and user.
3. Whether the allegations could support the intent-to-distribute element of the possession charge and the charged second-degree-murder offense.

Disposition

reversed_and_remanded