Drugs
893.13(1)(f) Drug Possession
1. (Defendant) possessed a certain substance.
2. The substance was (allege specific controlled substance).
3. (Defendant) had knowledge of the presence of the substance. Note: this issue is currently in litigation.
Upon resolution, the Police Legal Bureau will prepare and distribute a Legal Bulletin on the subject.
NOTE: With all drug abuse offenses, it is necessary to determine from the schedules in § 893.03 the identity of the applicable
controlled substance as the penalties vary depending on the identity of the controlled substance.
893.147(1) Possession of Drug Paraphernalia
1. (Defendant) used or had in his or her possession with intent to use drug paraphernalia (describe alleged paraphernalia).2. (Defendant) had knowledge of the presence of the drug paraphernalia.
893.13(1)(a) Drug Sale, Manufacture, Delivery, or Possession With Intent
1. (Defendant) (sold/purchased/manufactured/delivered/possessed with intent to sell/ possessed with intent to purchase/ possessed with intent to manufacture/possessed with intent to deliver) a certain substance.2. The substance was (name of controlled substance).
3. (Defendant) had knowledge of the presence of the substance. Note: this issue is currently in litigation. Upon resolution, the Police Legal Bureau will prepare and distribute a Legal Bulletin on the subject.
893.147(2) Drug Delivery Possession With Intent To Deliver, OR Manufacture With Intent To Deliever Drug Paraphernalia
1. (Defendant) (delivered/ possessed with intent to deliver/ manufactured with intent to deliver) drug paraphernalia (describe paraphernalia).2. (Defendant) had knowledge of the presence of the drug paraphernalia.
3. (Defendant) knew or reasonably should have known that the drug paraphernalia would be used to plant, propagate, cultivate, grow, harvest, manufacture, compound, convert, produce, process, prepare, test, analyze, pack, repack, store, contain, conceal, in inject, ingest, inhale or otherwise introduce into the human body (allege specific substance).