981 F.3d 476
6th Cir.2020Background
- In 2013 Thompson made two controlled heroin buys; police obtained a warrant for the apartment used in the transactions.
- Police stopped an SUV leaving the apartment; officers found bags of heroin and cocaine in the center console and sunroof.
- A loaded handgun was later found hidden under the back seat’s folding mechanism; Thompson’s fingerprints were not found on the gun.
- Thompson was convicted by a Michigan jury of three drug offenses and four gun-possession offenses (constructive possession).
- The Michigan Court of Appeals upheld the gun convictions, reasoning a jury could infer constructive possession from Thompson’s proximity to the gun and drugs plus the link between drug dealing and firearms; the Michigan Supreme Court denied review.
- Thompson filed a § 2254 habeas petition raising insufficiency-of-the-evidence and other claims; the district court denied relief and this Court granted a COA on the insufficiency claim only.
Issues
| Issue | Plaintiff's Argument (Thompson) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Sufficiency to prove constructive possession of firearm | Proximity to a hidden gun in a vehicle is insufficient; no evidence Thompson handled, used, or had fingerprints on the gun; passenger could have controlled it | Proximity plus indicia of control — Thompson was driver, drugs were next to him, and drug-dealing is commonly linked to firearms — suffices for a rational jury | Affirmed: under Jackson and AEDPA, a fair‑minded jurist could conclude jurors reasonably inferred constructive possession from proximity + drug-dealing nexus + driver status |
| Whether habeas review must be limited to the state court’s stated reasons (Wilson look‑through) | District court’s reliance on informant testimony (not used by state court) required remand because AEDPA review should focus on the state court’s actual reasons | A federal habeas court may independently assess the state court’s decision and may affirm on any reasonable ground; need not remand if the state court’s actual reasons are reasonable | No remand: this Court reviews the state court’s specific reasons and may affirm on other reasonable grounds; district court’s additional reasoning is not dispositive |
| AEDPA deference application | Argued state decision unreasonably applied Jackson given weak evidence | State: AEDPA requires deference; the state-court application was not objectively unreasonable | Held: Two layers of deference (jury factfinding and AEDPA) bar relief; state-court decision was not an unreasonable application of Jackson |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (establishes standard for sufficiency of the evidence review)
- People v. Hill, 446 N.W.2d 140 (Mich. 1989) (defines constructive possession as power and intent to exercise dominion or control)
- People v. Wolfe, 489 N.W.2d 748 (Mich. 1992) (proximity alone is insufficient to prove constructive possession)
- People v. Rapley, 767 N.W.2d 444 (Mich. 2009) (proximity to drugs plus the drugs‑guns relationship can support knowing possession)
- People v. LaFountain, 844 N.W.2d 5 (Mich. 2014) (recognizes the well‑known relationship between drug dealing and firearms)
- Parker v. Renico, 506 F.3d 444 (6th Cir. 2007) (habeas relief granted where evidence of constructive possession was speculative)
- Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA requires that state‑court legal rulings not be overturned unless objectively unreasonable)