Minor in Possession of Alcohol by Consumption

RCW 66.44.270 (2) (a) it is illegal to possess for athe defendant on the basis of insufficient
person under the age of 21 or consuming alcohol.evidence. According to the case of Roth:- Felony
This offense is accused commonly referred to aslawyer
a minor in possession, or MIP. Conviction for MIPThe accused has a controlled substance if he
may result in jail time, loss of license and theknows of the presence of the substance, the
health of fines. Law enforcement often makessubstance is immediately accessible, and the
the mistake of thinking that the law permits themdefendant exercises dominion and control over
to arrest and a small fee, if the minor hasthe substance. State v. Hornaday, 105 Wn.2d120,
consumed the signs of the issuing of alcohol. As125, 713 P.2d 71 (1986). The property can be
we shall see, makes this to be false.either constructive or actual. State v. Dalton, 72
The mere presence ofAlcohol in a system is notWn. App. 674, 676, 865 P.2d 575 (1994). Whether
sufficient to prove MIPthe defendant had possession of a substance is
The court in State v. Roth, 131 Wn. App. 556determined by the trier of the facts by the
(2006) with the question of whether evidencetotality of the circumstances must be examined.
that a small exhibition was treated under the signState v. Partin, 88 Wn.2d 899, 906, 567 P.2d 1136
of alcohol consumed sufficient to support a(1977). The mere presence of alcohol in a system
conviction under RCW 66.44.270 (2) too. In Roth,is not enough support on their own to a
the 20-year-old defendant went to a party whereconviction. Dalton, 72 Wn. App. at 676th However,
alcohol was present. No one saw the defendant isif evidence of prior consumptioncombined with
not to consume alcohol, but noticed Mr. Roth,other corroborating evidence, this may be
when she contacted the police that he staggeredsufficient to prove possession beyond a
and exude a strong odorAlcohol on the breath, soreasonable doubt. Id. No single factor is
they issued a ticket for MIP. Mr. Roth wasdeterminative of the existence of dominion and
convicted in the wake of the MIP in the districtcontrol. State v. Turner, 103 Wn. App. 515, 521, 13
court.- Felony lawyerP.3d 234 (2000). Emphasis Added.
On appeal, the Court annulled Roth conviction of