Criminal Law-Drug Possession-Sufficiency of Evidence

Staff Report//February 11, 2026//

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Defendant appealed his conviction for drug possession. Defendant was stopped by police in the parking lot of a closed business. Defendant’s passenger appeared intoxicated, and defendant was arrested for active warrants. Defendant denied consent to search his vehicle, so police called a canine unit that alerted to the presence of narcotics. Officers found methamphetamine within reach of the driver’s seat.

Where the location of the recovered drugs showed they were within defendant’s reach in the vehicle, and where the state presented other circumstantial evidence, including the passenger’s intoxication and defendant’s refusal to consent to a search, there was sufficient evidence for a jury to find that defendant had actual possession of the drugs.

Judgment is affirmed.

State v. Eggleston (MLW No. 84317/Case No. SC101152 – 16 pages) (Supreme Court of Missouri, Gooch, J.) Appealed from circuit court, Cole County, Beetem, J. (Christian E. Lemberg, Columbia for appellant) (Abigail Meharg and Evan J. Buchheim, Jefferson City for respondent)