What is the defence argument on the sufficiency of evidence in the case of possession of small amounts of heroin?

Defendant's argument on the sufficiency of the evidence is two-fold. Defendant first contends that the prosecution failed to sustain its burden of proving the quantity of narcotics involved. Defendant cites People v. Leal (1966) 64 Cal.2d 504, 50 Cal.Rptr. 777, 413 P.2d 665, for the proposition that the prosecution must prove that the quantity of heroin was suitable for use. People v. Leal is limited in its application to situations where the possession of narcotics were of minute traces or residue only. The

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