KNIGHT v. STATE (2026)

A jury found Leonardo Knight guilty of trafficking in fentanyl, trafficking in methamphetamine, possession of methamphetamine with intent to distribute, possession of cocaine with intent to distribute, possession of 3,4-MethyleneDioxy methamphetamine (“MDMA”) with intent to distribute, possession of codeine with intent to distribute, possession of amphetamine with intent to distribute, possession of oxycodone with intent to distribute, possession of more than one ounce of marijuana, and possession of a firearm during the commission of a felony, and the trial court sentenced him on these convictions. Knight appeals from the denial of his motion for new trial as amended. In his sole enumeration of error, Knight claims that the evidence was insufficient to support his convictions because only one of the drugs with which he was charged was lab-tested. For the reasons that follow, we affirm.

On appeal from a criminal conviction, the evidence must be viewed in the light most favorable to the verdict, and the defendant no longer enjoys the presumption of innocence; moreover, an appellate court does not weigh the evidence or determine witness credibility but only determines whether the evidence is sufficient under the standard of Jackson v. Virginia[, 443 U. S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979)]. Conflicts in the testimony of the witnesses, including the State's witnesses, are a matter of credibility for the jury to resolve. As long as there is some competent evidence, even though contradicted, to support each fact necessary to make out the State's case, the jury's verdict will be upheld. The testimony of a single witness is generally sufficient to establish a fact.

(Citation and punctuation omitted.) Riddle v. State, 267 Ga. App. 630, 630-31, 600 S.E.2d 709 (2004).

So viewed, the relevant evidence shows that police observed two men exit a car in a high drug crime area, enter a hotel with bags, exit the hotel with the bags shortly thereafter, get in their car, and drive away. An officer followed the car with his marked patrol unit, observed the car cross a white solid line, and initiated a traffic stop.¹ Knight was a passenger in the car, and an officer identified him in court as that passenger.

During the traffic stop, the officer discovered that the driver, Dante Marshall, had a suspended license. The officer testified that based on his prior observations of the men and their demeanor during the traffic stop, he had articulable, reasonable suspicion to believe that a crime had occurred, may be occurring, or would occur, and he asked Marshall if there were any narcotics in the vehicle. Marshall claimed the car was not his and he did not know what was in the vehicle. Marshall denied the officer's request to search the car. Knight told an officer that he had a gun under the seat that he was holding for someone. He also volunteered that he was out on bond for aggravated assault, though the officer later learned he was on bond for a number of narcotics charges. When the officer told Knight that he would have to step out of the car while the K-9 drug dog walked around to check for the odor of narcotics, Knight admitted that he had marijuana on him and pulled the marijuana “out of his midsection.”

The K-9 drug dog conducted an open-air sniff of the exterior of the vehicle and alerted to narcotics in the vehicle. At this point, the officer informed Marshall and Knight that he was going to search the car.² The officer discovered a book bag in the car that contained 146 grams of cocaine, 12 grams of crack cocaine, 46 grams of marijuana, 55 grams of fentanyl, 88 grams of methamphetamine, oxycodone, amphetamine, and codeine syrup. The book bag also contained new needles, two sandwich boxes consistent with the ones holding the narcotics, and a blender, glass pot, fork, burner, and baking soda, which the officer testified was used to break down narcotics for distribution. On Knight's person, the officer found a “large amount of currency” in separate bundles of different denominations, which he testified was consistent with “somebody who is profiting off of illegal narcotic sales.” Knight told the officer that the book bag belonged to his uncle. Both Marshall and Knight were arrested and transported to police headquarters.

The officer identified each of the narcotics at trial and testified that he recognized the substances as narcotics prior to testing; specifically, the officer testified at trial that State's Exhibit 7 contained three small bags of a substance he could not identify, State's Exhibit 8 was identified as fentanyl, State's Exhibit 9 was identified as methamphetamine, State's Exhibit 10 was identified as cocaine, State's Exhibit 11 was identified as MDMA, State's Exhibit 12 was identified as codeine syrup or promethazine, State's Exhibit 13 was identified as amphetamine pills, and State's Exhibit 14 was identified as oxycodone pills.³ When the officer returned to the station, he tested the narcotics using TruNarc, a machine in the police evidence room that uses infrared lighting to scan a substance and provide a chemical analysis to indicate whether the substance is a narcotic and the type of narcotic; the testing confirmed his identification of the narcotics.⁴ If the substance is not detected as a narcotic, the machine indicates that the testing is inconclusive. According to the officer, the only substance he could not identify — the one he “wasn't sure which type of narcotic it was” — was the substance in three small bags, and TruNarc testing came back as inconclusive so Knight was not charged with this substance. The substances were then submitted to the Georgia Bureau of Investigation (“GBI”) for testing. The officer testified that he has never had a substance that he sent for testing by the GBI show results for something that did not match the TruNarc result.

The GBI forensic chemist testified that the items were delivered to the GBI, but only the fentanyl was lab-tested. The substance was confirmed to be 54.867 grams of fentanyl. The result was peer-reviewed with the reviewer reaching the same conclusion on identity and weight. When asked why the GBI did not test the remaining substances, the chemist explained that due to a substantial backlog in the drug identification section, only the highest scheduled drug is typically tested under the current policy unless management approves a special request. In this case, the district attorney's office requested testing on the additional substances, but its request was denied.

Marshall testified at trial that he had been acquainted with Knight for only a few months prior to the traffic stop. Marshall knew that Knight “sold narcotics” for a living, and he had purchased methamphetamine from Knight “probably about three or four times.” According to Marshall, Knight had the book bag with the narcotics at his feet, but when they got pulled over, he “started shifting around and putting his bag behind [Marshall].” Marshall testified that he was “obviously aware of what [Knight] does and how he distributes it, so ․ [he was] sure there [was] something in the bag.”

Knight was indicted on twelve charges related to possession and distribution of narcotics, and he was convicted on ten of the charges. Knight appeals from the denial of his motion for new trial as amended.

In his sole enumeration of error, Knight asserts that the evidence was insufficient to support his convictions because he was convicted on numerous drug charges but only one drug was “tested and confirmed” by the GBI. Based on the evidence presented at trial, this argument lacks merit.

As an initial matter, we note that Knight has failed to provide any relevant citations of authority to support his argument in contravention of Court of Appeals Rule 25(d)(1): “Any enumeration of error that is not supported in the brief by citation of authority or argument may be deemed abandoned.” Knight's appellate argument simply contains a recitation of the facts and a few conclusory sentences, followed by citations to basic legal principles regarding circumstantial evidence and the State's burden of proof. Knight does not articulate a legal basis or cite to any relevant legal authority to support his implicit argument that the State was required to lab test each drug. “[M]ere conclusory statements are not the type of meaningful argument contemplated by our rules. Legal analysis is, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (Citations and punctuation omitted.) Rider v. State, 366 Ga. App. 260, 272, 883 S.E.2d 374 (2022); see also Cawthon v. State, 350 Ga. App. 741, 744, 830 S.E.2d 270 (2019) (holding that “an assertion of error followed by a legal citation is not legal analysis, which is, at a minimum, a discussion of the appropriate law as applied to the relevant facts”) (citation and punctuation omitted); Hester v. State, 304 Ga. App. 441, 444, 696 S.E.2d 427 (2010) (“Rhetoric is not a substitute for cogent legal analysis, which is, at a minimum, a discussion of the appropriate law as applied to the relevant facts.”) (citation and punctuation omitted). Nonetheless, we invoke our discretion to consider Knight's argument.

It is undisputed in this case that although the GBI tested and confirmed that one of the substances was, in fact, fentanyl, the GBI did not test the other substances due to its current policy as a result of case backlog. Nonetheless, we conclude that sufficient evidence was presented by the State, based on the officer's experience and training, as well as his TruNarc test results, for a rational trier of fact to find Knight guilty beyond a reasonable doubt of all the narcotics charges.

“It is well established that expert testimony is not necessary to identify a substance, including drugs. And even if police officers are not formally tendered as expert witnesses, if an adequate foundation is laid with respect to their experience and training, their testimony regarding narcotics is properly admitted.” (Citation and punctuation omitted.) Holmes v. State, 301 Ga. 143, 145, 800 S.E.2d 353 (2017) (finding sufficient evidence to establish substance was marijuana based on officer's field test despite officer's “unelaborate” foundation regarding his experience). In fact, in the recent case of Hutchins v. State, 374 Ga. App. 289, 290-92, 912 S.E.2d 164 (2025), this Court specifically rejected a defendant's argument that because a GBI forensic chemist did not chemically test the pills in question, the State did not prove that the pills were a controlled substance. In that case, we reiterated the well-settled principle that “expert testimony based on scientific tests is generally not required to identify the substance at issue in a drug possession case.” Id. at 291, 912 S.E.2d 164. “Positive test results from the State crime lab are not required.” Collins v. State, 278 Ga. App. 103, 104, 628 S.E.2d 148 (2006); accord Burg v. State, 298 Ga. App. 214, 216, 679 S.E.2d 780 (2009) (“[I]n drug possession cases[,] the State is not required to present expert testimony scientifically identifying the substance or to introduce the drugs into evidence.”). In that same vein, this Court repeatedly has held that a chemical field test alone is sufficient to support a conviction for selling or possessing narcotics. See Pate v. State, 318 Ga. App. 526, 527, 734 S.E.2d 255 (2012) (holding that a chemical field test was sufficient to support a conviction for selling or possessing cocaine); Sherrer v. State, 289 Ga. App. 156, 157-58, 656 S.E.2d 258 (2008) (holding that the State was not required to introduce a crime laboratory report showing that the seized, field-tested substance was methamphetamine); see also Lewis v. State, 233 Ga. App. 560, 562, 504 S.E.2d 732 (1998) (“We have found no case where the results of a chemical field test have been held inadmissible, though it would appear that its reliability would be tested by defense cross examination and rebuttal and that the weight to be given it by the jury would be an appropriate subject for defense argument.”) (citations and punctuation omitted).

Here, the officer who conducted the traffic stop testified that he had received extensive training and experience enabling him to identify various narcotics in the field. He trains 32 hours per month as a K-9 officer, using real narcotics that have been tested and weighed. According to the officer, he and his K-9 dog “train with numerous types of narcotics, not just one. We get to feel them, we get to see it. We get the consistency of it. We have different types of narcotics for different types of consistencies just so that we can become well known to the different types of narcotics.” The officer further testified that he had made “numerous narcotics arrests, and during those arrests, [he] handled the narcotics.”

Turning to this particular case, the K-9 drug dog alerted to narcotics during his open-air sniff, the officer located a book bag in the car containing narcotics, the officer identified each of the substances found in the book bag at trial, and the drugs were admitted into evidence without objection. While the officer did not perform chemical field tests, he testified at trial that he recognized the substances as drugs prior to testing them using the TruNarc machine at the police station, and the machine confirmed his identifications. According to the officer, the TruNarc test resulted in an inconclusive finding on the only substance he could not personally identify. In addition, the officer noted that he has never had a substance that he sent for GBI testing that tested for something other than the TruNarc result. Knight did not object to the officer's testimony or identification of the substances as narcotics, and “where, as was the case here, a witness testifies to a conclusion of fact which could be within his knowledge and such testimony is admitted without objection, it cannot be attacked on review as being incompetent or insufficient.” (Citation and punctuation omitted.) Burg, 298 Ga. App. at 216-17, 679 S.E.2d 780.

Even assuming that the evidence against Knight was entirely circumstantial, the jury was authorized to reject as unreasonable any alternative hypothesis posited by Knight as to the substances’ identities.⁵ “To warrant a conviction on circumstantial evidence, the proved facts shall not only be consistent with the hypothesis of guilt, but shall exclude every other reasonable hypothesis save that of the guilt of the accused.” OCGA § 24-14-6. “Whether the hypotheses are reasonable, however, are generally jury issues, with deference given to the jury's assessment of the weight and credibility of the evidence” and “[w]e will not disturb the jury's finding that the evidence excluded every reasonable hypothesis other than the guilt of the defendant unless it is insupportable as a matter of law.” (Citations and punctuation omitted.) Hutchins, 374 Ga. App. at 291, 912 S.E.2d 164.

In short, regardless of whether the GBI tested each substance, it was within the jury's discretion to decide, given the officer's testimony about his extensive training and experience, as well as the results of the TruNarc tests, that the substances found in the book bag and introduced by the State at trial were the narcotics with which Knight was charged. Lewis, 233 Ga. App. at 563, 504 S.E.2d 732; see also Ogburn v. State, 296 Ga. App. 254, 256, 674 S.E.2d 101 (2009) (“When the State tests only one of several bags of suspected methamphetamine with positive results, its failure to test the remaining bags does not render them inadmissible. Instead, the weight to be given such evidence is for the jury to determine.”) (citations omitted). “The jury obviously concluded that [the substances were the narcotics alleged by the State], and because we do not weigh the evidence on appeal, we conclude that there was sufficient evidence” to sustain Knight's convictions despite the fact that not all of the substances were lab-tested by the GBI.⁶ Lewis, 233 Ga. App. at 563, 504 S.E.2d 732; accord Hutchins, 374 Ga. App. at 290-91, 912 S.E.2d 164 (“[T]he reviewing court leaves to the jury the resolution of conflicts or inconsistencies in the evidence, credibility of witnesses, and reasonable inferences to be derived from the facts.”) (citation and punctuation omitted).

Judgment affirmed.

I agree with the majority that the evidence was sufficient to authorize Leonardo Knight's convictions. But I write specially to stress that the holding regarding the sufficiency of a chemical field test to support a conviction for selling or possessing narcotics addresses only that — the sufficiency of such evidence. To the extent that the authorities cited by the majority for that proposition also address the admissibility of such evidence, they have been superseded by our legislature's 2022 adoption of the Daubert standard to criminal trials. See OCGA § 24-7-702; Hayes v. State, 320 Ga. 505, 516 (3) (b), 910 S.E.2d 198 (2024). See also Daubert v. Merrell Dow Pharmaceuticals, 509 U. S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993).

FOOTNOTES

1.   On appeal, Knight does not challenge the traffic stop.

2.   On appeal, Knight does not challenge the search of the car.

3.   The exhibits were admitted without objection.

4.   On appeal, Knight does not challenge the results of the TruNarc testing.

5.   At trial, Knight repeatedly pointed out the lack of laboratory testing on the suspected drugs and argued that the State had failed to meet its burden of proof, both on that basis and also based on the location of the book bag in question.

6.   In a one-sentence conclusory argument devoid of any citations of authority, Knight asserts that his co-defendant Marshall, “an admitted drug abuser — turned [S]tate's witness — received probation, a disproportionate sentence that would clearly provide motivation for him to testify against [Knight].” This assertion, however, addresses his co-defendant's credibility, a matter exclusively within the province of the jury. See Reed v. State, 314 Ga. 534, 537 (1), 878 S.E.2d 217 (2022). The fact that the jury resolved credibility and evidence inconsistencies adversely to Knight does not render the evidence insufficient as a matter of law. Id. In fact, Marshall was questioned at trial about his motivations for testifying against Knight and contradictions in his testimony, with defense counsel implying during questioning and arguing to the jury during his closing that Marshall was hoping to obtain a favorable outcome in his own criminal case. It was the jury's prerogative to believe Marshall and disbelieve Knight. This claim, even if properly asserted, lacks merit.

Hodges, Judge.

Pipkin, J., concurs; and McFadden, P.J., concurs specially.