Isiah Williams v. State of Indiana (mem. dec.)
49A02-1606-CR-1204
| Ind. Ct. App. | Feb 27, 2017Background
- On July 14, 2015, IMPD officers surveilled Bryisha Dickerson’s apartment and vehicle to execute a warrant; Isiah Williams (using crutches) exited the apartment and entered Dickerson’s car as officers arrived.
- Officer Scott stopped the vehicle, ordered Williams to show his hands, and observed Williams leaning toward the passenger-side floorboard where a handgun was visible.
- Officers secured Williams; during a pat-down, Williams pointed to the handgun and said, “Yes, I have one right there.” Marijuana was also found on Williams; the handgun later yielded no fingerprints.
- Dickerson testified the gun was a gift she received earlier that day and that a friend placed it in the car; the trial court found her not credible and noted inconsistencies in her testimony.
- Williams was convicted after a bench trial of carrying a handgun without a license (Class A misdemeanor) and possession of marijuana; he appealed only the handgun conviction, arguing insufficient evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved Williams constructively possessed the handgun | State: Evidence (gun in plain view, Williams’ reaching motion, his admission pointing to gun) supports constructive possession | Williams: Gun belonged to Dickerson/third party; reaching motion could be positioning himself, not for the gun | Affirmed: Constructive possession proven by location, proximity, admission, and control of vehicle key |
Key Cases Cited
- Jackson v. State, 925 N.E.2d 369 (Ind. 2010) (standard for sufficiency-of-evidence review)
- Gray v. State, 957 N.E.2d 171 (Ind. 2011) (constructive possession requires capability and intent; intent may be inferred from possessory interest)
- Deshazier v. State, 877 N.E.2d 200 (Ind. Ct. App. 2007) (possession may be actual or constructive)
- Grim v. State, 797 N.E.2d 825 (Ind. Ct. App. 2003) (proximity and plain view of firearms support conviction for carrying without a license)
- Gorman v. State, 968 N.E.2d 845 (Ind. Ct. App. 2012) (consider probative evidence and reasonable inferences supporting conviction)