Supreme Court of Florida

Michael Anthony Conage v. United States

August 25, 2022346 So. 3d 594

Summary

The court held that a completed purchase under Florida's drug-trafficking statute requires both consideration and the defendant's obtaining control over the drugs, including control constituting constructive possession under federal law. It rejected the argument that payment alone completes the purchase and explained that statutory meaning must be determined using textual and structural context rather than by isolating a supposedly clear term. The court answered the certified question accordingly.