Adrian Tamilrah Moore a/k/a Adrian Moore a/k/a Adrin Moore v. State of Mississippi

Summary

The Mississippi Court of Appeals affirmed Adrian Moore’s convictions for heroin trafficking, methamphetamine possession, and PCP possession. The court held that the stipulated forensic laboratory report and evidence concerning homogeneous pills were sufficient to support the heroin and methamphetamine convictions, despite testing only some dosage units. The court also held that the indictment and evidence sufficiently established possession of ten or more dosage units of PCP because Mississippi law defines one milliliter of liquid solution as one dosage unit.

Holdings

1. Moore's challenge was waived and independently barred by the invited-error doctrine; no plain error occurred because no legal rule barred a defendant from stipulating to the admissibility of a drug-analysis report.
2. The evidence was sufficient for a rational juror to find beyond a reasonable doubt that Moore possessed 40 or more dosage units of heroin.
3. The evidence was sufficient for a rational juror to find beyond a reasonable doubt that Moore possessed at least 20 dosage units of methamphetamine.
4. The evidence supported Moore's PCP conviction because Mississippi law defines one dosage unit of a liquid solution as one milliliter; 13 milliliters therefore constituted at least ten dosage units.

Questions Presented

1. Whether sufficient evidence supported Moore's heroin-trafficking conviction when only three of 43 heroin dosage units were tested.
2. Whether sufficient evidence supported Moore's methamphetamine-possession conviction when only three of 28 methamphetamine dosage units were tested.
3. Whether sufficient evidence supported Moore's PCP-possession conviction when the PCP was liquid and the indictment alleged possession of ten or more dosage units.
4. Whether Moore's challenges to the laboratory report and testing procedures were waived, procedurally barred, or subject to plain-error review.

Disposition

affirmed