United States v. Dorman
United States Court of Appeals for the District of Columbia Circuit
860 F.3d 675 (2017)
Police investigating a robbery searched Harold Dorman's (defendant) mother's house, where Dorman sometimes slept but which was not his only residence, and where he was not present at the time. Officers found a concealed handgun and small vial of PCP upstairs, a larger bottle of PCP hidden by the laundry machine, a pistol under the mattress in Dorman's usual room, and empty vials for packaging PCP hidden on the basement stairs. Dorman was convicted of gun possession, PCP possession with intent to distribute, and possessing a gun during drug trafficking; he appealed the two drug-related convictions.
Whether a conviction for the constructive possession of illegal drugs requires proof that the defendant knew of and was in a position to exercise dominion and control over the contraband.