Thursday, November 21, 2013

United States v. Maldonado case brief

United States v. Maldonado case brief summary
23 F.3d 4 (1994)


CASE SYNOPSIS
Defendant appealed his conviction from the United States District Court for the District of Puerto Rico for possession of cocaine with intent to distribute in violation of 21 U.S.C.S. § 841 arguing that the evidence failed to show possession.

CASE FACTS
A jury convicted defendant of possession of cocaine with intent to distribute, in violation of21 U.S.C.S. § 841(a)(1). Defendant argued that the evidence was insufficient to support the conviction on grounds of insufficient evidence to prove possession. The conviction for possession could stand only if a reasonable jury could find that defendant did possess the cocaine within the meaning of 21 U.S.C.S. § 841. There was no evidence that he even touched the bag or saw the cocaine or that he was ever alone in the room with it or that he had a practical opportunity to remove it from the hotel.

RULE
  • Under settled law, possession included not merely the state of immediate, hands-on physical possession but also constructive possession, including possession through another, and joint as well as exclusive possession. 
DISCUSSION
  • The judgment was affirmed because the drugs were left in defendant's room with his knowledge and consent while defendant was awaiting the arrival of an accomplice to pay for them. 
  • It was also fair to describe the location as defendant's hotel room because he was effectively in occupation and the jury could reasonably infer that he could return there at will.

CONCLUSION
Defendant's conviction for possession of cocaine with intent to distribute was affirmed because the drugs were found in a hotel room that defendant occupied and were left in the room with defendant's consent and knowledge.

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