State Not Required to Prove Knowledge or Intent In Case of Prohibited Act of Delivering Unlawful Barbiturate

In State v. Medlin, 273 So. 2d 394 (Fla. 1973), the defendant gave a capsule to another person, and it contained an illegal substance. Despite the fact that Medlin told the other person that the capsule would make her "go up," Medlin argued that there was no proof at trial to show that he delivered the capsule with knowledge that it contained a barbiturate. Medlin was convicted of delivery of an unlawful barbiturate. The district court reversed the conviction finding that there was no proof adduced to show that Medlin delivered the capsule with knowledge that it contained a barbiturate or barbiturate derivative. On review, this Court quashed the district court's decision and held that the State was not required to prove knowledge or intent since both were presumed from the doing of the prohibited act. In Medlin, the defendant was convicted of unlawful delivery of a barbiturate. It was undisputed that he gave another person a barbiturate capsule, stating that it would make her "go up." on appeal, the district court reversed the conviction because no proof was adduced at trial to show that the defendant delivered the capsule with knowledge that it contained a barbiturate. However, on review, this Court quashed the district court's decision, holding: Proof that defendant committed the prohibited act raised the presumption that the act was knowingly and intentionally done. . . . . . . the State was not required to prove knowledge or intent since both were presumed from the doing of the prohibited act. Id. at 397. Importantly, the Court limited this presumption by distinguishing Medlin's case, which involved actual possession, from other cases in which possession was constructive. Id. at 395-96.