Adams v. State, 946 N.E.2d 630

Adams was a passenger in a car stopped for speeding.
An officer smelled raw marijuana and saw a jar containing marijuana on the front passenger floorboard.
The marijuana was in plain view; Adams and the driver denied illegal substance, while the driver admitted smoking earlier in the car.
Adams was front-seat passenger; the marijuana’s location and Adams’ proximity supported potential constructive possession.
Adams was convicted of Class A misdemeanor possession of marijuana and the court suspended most of the sentence; license and vehicle registration were suspended for 180 days under Ind. Code § 35-48-4-15.
The Indiana Court of Appeals affirmed both the conviction and the license/registration suspension.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is sufficient evidence of possession	Adams argues insufficient evidence to prove possession.	Adams contends lack of actual possession and unclear ownership.	Yes; sufficient evidence of constructive possession.
Whether § 35-48-4-15 applies to Adams	State says vehicle used in crime; suspension required.	Adams argues statute requires vehicle use by the offender in a meaningful sense; he was a passenger.	Yes; vehicle used to transport marijuana; suspension upheld.

Lampkins v. State, 682 N.E.2d 1268 (Ind. 1997) (construction of possession and proximity factors supporting intent and control)
Henderson v. State, 715 N.E.2d 833 (Ind. 1999) (incriminating statements/behavior showing dominion over contraband)
Deshazier v. State, 877 N.E.2d 200 (Ind.Ct.App.2007) (passenger possession inference when contraband visible and owner unclear)
Godar v. State, 643 N.E.2d 12 (Ind.Ct.App.1994) (evidence of possession where contraband is in plain view)
Cantrell v. Putnam Cty. Sheriff's Dept., 894 N.E.2d 1081 (Ind.Ct.App.2008) (vehicle used to transport drugs supports seizure/use in crime analogy)
$100 v. State, 822 N.E.2d 1001 (Ind.Ct.App.2005) (transportation of marijuana within vehicle supports vehicle-use finding)