Steven Marcus Densonv.The State
Steven Marcus Denson was convicted of trafficking in methamphetamine after police found him in a bathroom of a house containing chemicals and equipment associated with a methamphetamine lab. The trial court did not resolve his motion for new trial for nearly ten years, and Denson had completed his sentence by the time of appeal. The Georgia Court of Appeals nevertheless exercised its discretion to hear the case. It held that the evidence showed only Denson’s presence at the scene and did not permit a reasonable jury to infer that he knowingly participated in trafficking or manufacturing methamphetamine. The court distinguished cases containing additional incriminating circumstances, such as evidence that the defendant lived at the house, acted nervously, warned others, or suffered a production-related burn. The court reversed the conviction and noted that the extraordinary delay illustrated the constitutional concern that justice delayed can be justice denied.
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