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Keywords

appealtrial
defendantappealtrialjury trial

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Dawkins v. State, 313 Md. 638, 547 A.2d 1041

Facts

Leonard C. Dawkins was arrested in a hotel room in Baltimore City and charged with possession of heroin and possession of controlled paraphernalia. During the trial, police found narcotics paraphernalia and heroin residue in a tote bag that Dawkins claimed belonged to his girlfriend. Dawkins testified that he was unaware of the bag's contents and that he had only been in the room for a short time before the police arrived. The jury was instructed on the elements of possession but not on the requirement of knowledge, leading to his conviction.

The defendant, Leonard C. Dawkins, was arrested in a hotel room in Baltimore City and charged with possession of heroin and possession of controlled paraphernalia. At the defendant's jury trial in the Circuit Court for Baltimore City, the police testified that when they entered the hotel room, the defendant held a tote bag in his hand. The police proceeded to search the tote bag, and they found in it narcotics paraphernalia and a bottle cap containing heroin residue.

Issue

Whether 'knowledge' is an element of the offenses of possession of a controlled dangerous substance and possession of controlled paraphernalia under Maryland Code.

The issue in this case is whether 'knowledge' is an element of the offenses of possession of a controlled dangerous substance and possession of controlled paraphernalia under Maryland Code (1957, 1987 Repl.Vol.), Art. 27, § 287 (a) and (d).

Rule

Knowledge is an essential element of the offenses of possession of controlled dangerous substances and possession of controlled paraphernalia under Maryland law.

We hold that 'knowledge' is an element of the offenses charged in this case.

Analysis

The court determined that the jury should have been instructed that knowledge is a necessary element for conviction. It reasoned that an individual cannot exercise dominion or control over an object if they are unaware of its existence. The court also noted that the statutory scheme implied a requirement of knowing possession, as one cannot intend to use an object if they do not know they possess it.

We find persuasive the reasoning of the above-reviewed cases. In particular, we agree that an individual ordinarily would not be deemed to exercise 'dominion or control' over an object about which he is unaware.

Conclusion

The Maryland Court of Appeals reversed the decision of the Court of Special Appeals and remanded the case for a new trial, emphasizing that Dawkins was entitled to an instruction that knowledge is an element of the offenses charged.

JUDGMENT OF THE COURT OF SPECIAL APPEALS REVERSED, AND CASE REMANDED TO THAT COURT WITH DIRECTIONS TO REVERSE THE JUDGMENT OF THE CIRCUIT COURT FOR BALTIMORE CITY AND REMAND THE CASE TO THE CIRCUIT COURT OF BALTIMORE CITY FOR A NEW TRIAL.

Who won?

Leonard C. Dawkins prevailed in the case because the court recognized that the jury was not properly instructed on the element of knowledge, which is essential for the offenses he was charged with.

The defendant Dawkins was entitled to an instruction that knowledge is an element.

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