Rangel v. State, 110 So. 3d 41

Rangel was convicted of possession of cocaine and sale of cocaine within 1000 feet of a place of worship after a confidential informant purchased crack from him in a Taco Bell parking lot.
The cocaine ecgonine was found in a liquid in a caddy containing car cleaning products, located on the front passenger floorboard where Rangel sat.
A traffic stop followed the informant’s delivery; Rangel was in the front passenger seat and rummaged near the floor where the container was found.
No fingerprints or incriminating statements linked Rangel to the container; other occupants were present in the vehicle.
The trial court denied a judgment of acquittal on possession; Rangel was convicted of possession and, separately, of sale within 1000 feet of a place of worship.
On appeal, the court reversed the possession conviction due to lack of sufficient independent proof of dominion and control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for constructive possession	Rangel lacks knowledge and dominion over the container.	Independent proof linked Rangel to the container via proximity and movements.	Constructive possession not proven; reversal of possession conviction

Murphy v. State, 511 So.2d 397 (Fla. 4th DCA 1987) (evidence from which knowledge may be inferred in constructive possession cases)
Brown v. State, 8 So.3d 1187 (Fla. 4th DCA 2009) (closed container concealment requires stronger link to ownership/possession)
Culver v. State, 990 So.2d 1206 (Fla. 2d DCA 2008) (lack of independent proof undermines dominion evidence)
Meme v. State, 72 So.3d 254 (Fla. 4th DCA 2011) (circumstantial evidence with suspicious behavior can support dominion inference)
Nicholson v. State, 33 So.3d 107 (Fla. 1st DCA 2010) (plain-view drug presence can support knowledge of contraband in shared space)
Toole v. State, 472 So.2d 1174 (Fla.1985) (judgment of acquittal proper when no evidence of dominion and control)