Source: cases/21usc841/f3d-915-1172-us-v-solis.case
Case source: https://www.neochart.com/catalog/cases/f3d/volume_915/1172_01/index.html
The government may prove knowing possession by showing constructive possession-that is, that Solis had both knowledge of and control over the contraband.
Accordingly, a reasonable jury could find that Solis had knowledge of and control over the methamphetamine.
Here, unlike in Ramos, the evidence supported a finding that Solis: knew that Pedraza had purchased methamphetamine in Dallas; allowed Pedraza to store the drugs in her vehicle; knew that the drugs were stashed in her children's car seats; and had access to those car seats.
casedsl 1.2 # author: Flash2 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /f3d/915/1172-01 name United States v. Solis cite 915 F.3d 1172 (2019) court United States Court of Appeals for the Eighth Circuit date 2019-02-13 url catalog/cases/f3d/volume_915/1172_01/index.html source ir/caselaw/f3d_915.jsonl sha1=ee6c5e7a85e42fbe57e177a412da9f3f774fb3e7 chars=15675 opinion maj : per-curiam @0..15675 controlling ? opinion: the last paragraph @15584..15675 is the opinion's own footnote appended by the IR; one span. law 21usc841 (a)(1) & (b)(1)(A) role applied posture criminal; jury convictions for conspiracy (ยง 846) and possession with intent to distribute methamphetamine; on appeal defendant challenges sufficiency of the evidence of knowing (constructive) possession and the refusal of a "mere presence" instruction; drug convictions affirmed (separate misprision conviction reversed on Fifth Amendment grounds) result claimant-won element possession : satisfied [proved] route constructive pattern drugs-hidden-in-childrens-car-seats-in-defendants-vehicle fact @3022..3176 [supports] | Using the cordless drill and the Phillips bit, he disassembled the car seats and found $19,000 in rubber-banded cash and 2.5 kilograms of methamphetamine. fact @1837..2012 [supports] | Using one of Solis's vehicles, Pedraza drove Solis and two of her children to Dallas, Texas, on July 17, 2015, where he planned on purchasing ten kilograms of methamphetamine. fact @2806..2849 [supports] | Solis consented to a search of the vehicle. rule @5675..5828 | The government may prove knowing possession by showing constructive possession-that is, that Solis had both knowledge of and control over the contraband. rule @5893..6032 [quoted] | Mere presence or physical proximity alone cannot support such a finding. There must be "some nexus between a defendant and the contraband." held @6663..6770 | Accordingly, a reasonable jury could find that Solis had knowledge of and control over the methamphetamine. gloss Sufficiency upheld: the drugs were in the children's car seats of defendant's own vehicle on the return leg of a drug-buying trip she joined; the court found the nexus (knowledge plus access/control) that mere joint occupancy lacks. element knowledge : satisfied [proved] route circumstantial pattern knew-boyfriend-purchased-drugs-stashed-in-her-vehicle fact @2307..2475 [supports] | After Pedraza, Solis, and the children arrived in Dallas, DEA agents intercepted a phone conversation in which Solis asked Pedraza if he had "fix[ed] everything there." fact @3177..3240 [supports] | He found another $1,796 in rubber-banded cash in Solis's purse. held @6388..6662 | Here, unlike in Ramos, the evidence supported a finding that Solis: knew that Pedraza had purchased methamphetamine in Dallas; allowed Pedraza to store the drugs in her vehicle; knew that the drugs were stashed in her children's car seats; and had access to those car seats. gloss Circumstantial evidence established knowledge of the contraband concealed in the vehicle. element intent-to-distribute : satisfied [proved] decider jury review none route inferred-from-quantity-and-circumstances pattern two-and-half-kilograms-methamphetamine-in-car-seats fact @3022..3176 [supports] | Using the cordless drill and the Phillips bit, he disassembled the car seats and found $19,000 in rubber-banded cash and 2.5 kilograms of methamphetamine. fact @2850..3021 [supports] | After the trooper found a cordless screwdriver with a single Phillips bit and a suitcase containing Ziploc bags, he examined the car seats and found them abnormally heavy. gloss Jury finding only: on appeal Solis attacked knowing possession, not intent to distribute, and the court does not discuss it.