didn't go to church that day but i did observe people coming and going on that day from the church so i think that the inferences that can be drawn from that testimony go a little bit further than what was  i just think the issues here so the criminal statute defines the elements of what facts constitute a criminal and jackson regulates what is the amount of the state needs look forward to establish the particulars so i don't think there's actually a disagreement between the parties about what the elements of the crime the people have to prove that controlled substance was delivered within a thousand people church and the parties agreed that the most reasonable definition of church is a place whose primary use is is for religious wors example in a murder case you might have a witness testify i saw the defendant running from the scene of the crime the gunman and then i saw the victim the shop people have to prove that the defendant actually caused the death of the victim but it's perfectly reasonable for a jury to infer based on that evidence that it was the who committed a crime at the same way here the jury panel see the architecture of the church and see the sign  you really is now saying that this argument improperly shifts the state's burden to prove the case to the defendant to prove you know you argued that they should cross examination have done this they should have done that but isn't that shifting the burden no your honor when we we absolutely agree that the burden is always on the people to prove it's all the elements of the offense but you know there's doesn't seem to be any evidence of abuse actual abuse just that's what he means when he says this is a church he means this is a building that is useful it is worth it because that that's what the definition of church is and the church is something that the jurors lay witnesses have experience with in their own lives in their neighborhoods in their communities what the church looks like and what goes on at a church it's not some specialized thing that that you need an expert witness or a pastor to come in and gun it's something that a witness can identify and testify about  and so to answer justice thomas question about argument there's nothing that needs to be overruled all the way to think it's important to clarify that portion of parliament that the defendant is relying on with dealing with the statutory interpretation question of whether the school in hard was in fact a school and it wasn't dealing with what is the question in this case which is whether there was sufficient evidence that this trip with each and that was the only characterized i think about leading questions or compound questions or hearsay questions you'd end up hearing all sorts of sufficiency challenges about the state not asking the questions in the proper way  first the first drug deal that took place in december presumably because they read that there wasn't sufficient evidence to show that he had been personally involved but there was no testimony was he was within his rights three the argument here but i do think that it it shows that this was not an issue that this was not an actual issue that was contested  that we think jackson as protection for the defendant to make sure that the trial's getting to the truth it doesn't have any role here because this is not this is not an issue and that's just not necessary just make trials longer and more burdensome every single fact has to be proven with with the best possible evidence even if there's no dispute about what happened on  yes my argument would feel but there must be some logical grounds for why the oil would suggest that that language is not used and again i would want to quote it back to people before the purpose of that