Case Brief :Stopped for Speeding Accused of Illegally Possessing Firearms
When they were stopped for evidence of a speeding violation, threeadult males and a sixteen-year-old girl, henceforth known as 'Jane Doe',were accused of illegally possessing firearms. Two loaded handguns and amachine gun (as well as a pound of heroin) were found in an automobile inwhich they were riding when it was stopped for speeding. The guns had beenpositioned crosswise in Jane Doe's open handbag on either the front flooror front seat on the passenger side where she was sitting. All were jointlytried in a New York state court on charges of illegally possessing these All four defendants objected to the introduction of the guns intoevidence, arguing that the State of New York had not adequatelydemonstrated a connection between themselves and the guns. When this
Holding: The trial court overruled the four defendant's first objection,relying on the presumption of possession created by a New York statuteproviding that the presence of a firearm in an automobile is presumptiveevidence of its illegal possession by all persons then occupying thevehicle, except when the firearm is found upon the person of one of theoccupants. respondents then filed a habeas corpus petition inFederal District Court, contending that they were denied due process of lawby the application of the statutory presumption. Rationale: Besides affirming the presumption of possession, given thecircumstances, the court also court concluded that the applicability of theexception was a question of fact for the jury to decide, not to be decidedbefore the case went to the jury. Regarding the writ of habeas corpus later filed, the District Courtissued the writ, stating that the respondents had not deliberately bypassedtheir federal claim by their actions at trial and that the mere presence oftwo guns in a woman's handbag in a car could not reasonably give rise tothe inference that they were in the possession of three other persons inthe car. United States Court of Appeals found that District Court hadjurisdiction to entertain respondents' claim that the statutory presumptionis unconstitutional and that the United States Court of Appeals erred. In other words, the circumstances werenot clear in terms of a question of fact, as to who possessed the gun. The United States Court of Appeals affirmed, holding that the NewYork Court of Appeals had decided respondents' constitutional claim on itsmerits rather than on any independent state procedural ground that mighthave barred collateral relief and, without deciding whether the presumptionwas constitutional as applied in this case, that the statute isunconstitutional on its face. Conclusion After being instructed that the jury, if it so desired, was entitledto infer possession from the defendants' presence in the car the juryconvicted all four defendants of illegal possession of the handguns. Court of Appeals held, as applied to the facts of this case, thestatutory presumption was constitutional and that under the circumstances,the jury would have been entirely reasonable in rejecting the suggestionthat the guns were in Jane Doe's sole possession, stating it was surelyrational to infer that each of the respondents was fully aware of the guns'presence and had both the ability and the intent to exercise dominion andcontrol over them. The trial court also denied respondents' motion to dismiss thecharges on the alleged ground that such exception applied because the gunswere found on Jane Doe's person.
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