The Indiana Court of Appeals has affirmed a woman’s drug possession convictions after a traffic stop led to the discovery of contraband in a purse that the trial court inferred to be hers.
Lindsay Grubbs had been a passenger in a vehicle that was pulled over after police checking her license plates belonged on a different car. She eventually found herself with drug possession charges after an officer discovered drug-related materials in a purse sitting on her lap.
The vehicle was set to be towed and an Indianapolis Metropolitan Police officer proceeded to inventory all contents in the vehicle as required. That included the items in bags and purses sitting in the backseat of the car where Grubbs had been. Inside one purse, the officer found a glass pipe used for smoking narcotics and “a baggie with white powder residue in it” that later tested positive for methamphetamine.
Grubbs was charged with Level 6 felony possession of methamphetamine and Class C misdemeanor possession of paraphernalia. A trial court lowered her felony charge to a Class A misdemeanor because it was Grubbs’ first felony conviction. On appeal, Grubbs argued that the state had insufficient evidence to prove she knew what was in the purse, arguing the only evidence of constructive possession was her close proximity to the contraband.
Additionally, Grubbs added that the backseat had been full of bags containing personal belongings, and that there was evidence to prove she knew what was in the bag on her lap. The Indiana Court of Appeals rejected that argument by pointing out Grubbs failed to acknowledge the bag she was holding was a purse, rather than a trash bag or suitcase.
“When there were two women and two purses in the car and Grubbs had one purse on her lap, the only reasonable inference is that the purse Grubbs was holding was her own,” Judge Melissa May wrote for the court. “Grubbs argues the State failed to prove she knew the methamphetamine and pipe were in the purse, such that she could have knowingly possessed those illegal items; however, when we have already concluded the evidence supports a reasonable inference that Grubbs was holding her own purse, such evidence also supports the inference that Grubbs knew what was inside her own purse.”
The appellate court therefore found sufficient evidence supported Grubbs’ conviction and thus affirmed it in Lindsay N. Grubbs v. State of Indiana,19A-CR-572.