United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998

United States Court of Appeals for the Eighth Circuit · 1998-07-28

21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)

Original case on neochart.com

Case and law context

21 U.S.C. § 841

Role: applied; posture: criminal; jury conviction for possession of methamphetamine with intent to distribute; defendant challenges sufficiency of evidence on constructive possession; conviction reversed; result: claimant-lost; claim: (a)(1)

Uncertainty

None recorded

Misfit

None recorded

B · Case × element grid

Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.

Elements 1–6 of 18

21 U.S.C. § 841
CaseMens rea: "knowingly or intentionally" (including knowledge that the substance is a controlled substance)Controlled substance (21 U.S.C. §§ 802(6), 812 Schedules I-V) or counterfeit substance (§ 841(a)(2))Authorization exception ("Except as authorized by this subchapter") for registered practitioners/handlersPossession (actual, constructive, sole, or joint dominion and control)Specific intent to manufacture, distribute, or dispense the possessed controlled substancePartial penalty-tier drug type and quantity table (selected § 841(b)(1)(A)-(D) hook)
United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))
○ not reached · basis not recordedNot counted: applied/merits
○ not reached · basis not recordedNot counted: applied/merits
· not addressed
○ not reached · basis not recordedNot counted: applied/merits
· not addressed

Elements 7–12 of 18

21 U.S.C. § 841
CaseDeath or serious bodily injury results from the use of such substance (§ 841(b)(1)(A)-(C) 20-year mandatory minimum)Recidivist enhancement for prior conviction for a serious drug felony or serious violent felony (§ 841(b)(1), 21 U.S.C. § 851)Prohibited act under § 841(a)(1): manufacture, distribute, or dispenseCross-statute route alias: see separate aiding-abetting (§ 2) and x-conspiracy-846 (§ 846) routesAiding and abetting route under 18 U.S.C. § 2 (cross-statute)Categorical / modified categorical comparison of state drug offense to 21 U.S.C. § 841 (INA / ACCA / Guidelines)
United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 13–18 of 18

21 U.S.C. § 841
CaseDrug conspiracy route under 21 U.S.C. § 846 (cross-statute)Fifth Amendment Due Process / Equal Protection challenge to carrier-medium weight sentencing (Chapman)Affirmative defense of entrapment (government inducement + lack of predisposition)Rule of lenity in construing ambiguous penalty provisions of § 841(b)Fifth Amendment void-for-vagueness challenge to "mixture or substance" or analogue provisionsContinuing-offense venue for § 841(a)(1) possession with intent to distribute / distribution (18 U.S.C. § 3237(a))
United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 — not reached (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Specific intent to manufacture, distribute, or dispense the possessed controlled substancenot_reached
Excluded from merits counts
applied / merits

claim: (a)(1)

Vacated with the failure of proof on possession.
Unspecified routeNo source quotation recorded for this block.
United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 — not reached (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Mens rea: "knowingly or intentionally" (including knowledge that the substance is a controlled substance)not_reached
Excluded from merits counts
applied / merits

claim: (a)(1)

Addressed only as intent to gain future possession; not separately reached.
Unspecified routeNo source quotation recorded for this block.
United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 — not · no-evidence (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Possession (actual, constructive, sole, or joint dominion and control)not
Counted merits instance
applied / merits

basis: no-evidence; claim: (a)(1)

Conviction reversed for insufficiency of evidence: where a mailed package was addressed to a third party and turned over to police before defendant could assert control or reduce it to actual possession, defendant had at most intent or hope to gain possession, which does not constitute constructive possession.
intercepted-delivery-before-defendant-exerted-control
Neither Quintanar’s name nor his address was on the box. He never touched it or handled it.
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [6112:6203] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: fact; polarity: cuts-against; absent flag: 1; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

But before Quintanar could assert dominion or control of the package it was physically removed from the possession of Macias and taken to the police station.
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [8746:8903] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Quintanar then told her that there were drugs in the box, “[he] asked me just to give — just to turn the box over to him, not to destroy him.”
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [5011:5153] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Connett was not acting on his behalf but at the direction of Hoffman.
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [8613:8682] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

The government’s case straightforwardly rests upon constructive possession. Therefore, for the jury to find Quintanar guilty, the government was required to prove that Quintanar intended to exercise dominion over the methamphetamine, that he had the power to exercise dominion, and that he.knew he had the power to exercise dominion.
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [7649:7982] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

“[T]he essence of constructive possession is not direct, physical control, but the ability to reduce an object to actual possession; otherwise, constructive possession would have no meaning at all- It is enough if one person is sufficiently associated with another having physical possession that he is able to produce a controlled substance for a customer.”
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [10565:10923] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 1 (1 = tagged; 0 = not tagged)

The government’s evidence fell short of proving beyond reasonable doubt that Quintanar had the power to exercise control or dominion over the drugs at any given time.
Source: docroot/ir/caselaw/f3d_150.jsonl#/f3d/150/0902-01; Unicode character offsets [8141:8307] (end exclusive); SHA-256 8660efadd6fa9dcf4539515752f4b0ebe3fc8238977002fcbcca3aa1d0996a8b.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

United States v. Quintanar — 150 F.3d 902 (1998) · United States Court of Appeals for the Eighth Circuit · 1998 — not reached (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Controlled substance (21 U.S.C. §§ 802(6), 812 Schedules I-V) or counterfeit substance (§ 841(a)(2))not_reached
Excluded from merits counts
applied / merits

claim: (a)(1)

Methamphetamine in package not contested.
Unspecified routeNo source quotation recorded for this block.

Court interpretations recorded from this case