Woodruff v. State

Summary

The Oklahoma Court of Criminal Appeals affirmed Leonard J. Woodruff Jr.'s conviction for unlawful delivery of amphetamine. The court held that evidence of a subsequent similar drug transaction was admissible to show a common scheme or plan, that the evidence sufficiently supported the conviction, and that the trial court properly replayed the portion of testimony requested by the jury. The court also rejected the defendant's motion-for-mistrial argument.

Holdings

1. Evidence of a subsequent, similar offense was properly admitted because it was material to show a common scheme or plan and was sufficiently related to the charged offense that proof of the subsequent offense tended to establish the charged offense.
2. The evidence was sufficient to support Woodruff's conviction for unlawful delivery of amphetamine while acting in concert with West.
3. The trial court properly replayed only the portion of the witness's testimony requested by the jury and was not required to replay the cross-examination when the jury did not request additional testimony.
4. The denial of the motion for mistrial was proper because the evidence of the subsequent offense was properly admitted.

Questions Presented

1. Whether evidence of Woodruff's subsequent amphetamine delivery in Norman was inadmissible evidence of another crime.
2. Whether the evidence was sufficient to support Woodruff's conviction for unlawful delivery of a controlled dangerous substance while acting in concert with West.
3. Whether the trial court improperly allowed the jury to hear only the portion of the agent's testimony that it requested during deliberations, rather than also replaying the cross-examination.
4. Whether the trial court erred in denying Woodruff's motion for a mistrial based on the admission of evidence of another offense.

Disposition

affirmed