United States v. Clark
United States Court of Appeals for the Second Circuit
740 F.3d 808 (2014)
Police arrested Jeremiah Clark (defendant) in connection with a reported assault; a patdown found nothing, and officers handcuffed him securely (with barely an inch and a half of chain between the cuffs) and drove him about one minute to the station in a squad car that had been checked and confirmed clean beforehand. After Clark got out, officers found a bag of crack cocaine wedged under the seat, with some powder spilled nearby, though no cocaine dust had been seen on the seat or on Clark's clothes, and a search at the station turned up no drugs on Clark himself. The jury convicted Clark of drug possession, and he challenged the sufficiency of the evidence on appeal.
Whether a jury can find beyond a reasonable doubt that a securely handcuffed defendant possessed drugs discovered under a car seat when no drugs were ever found on his person.