State of Iowa v. David Dwight Jackson, 16-1150

In Feb 2016 police executed a search warrant on a Des Moines apartment and found David Dwight Jackson seated in the only bathroom; officers discovered 6.97 g methamphetamine and $303 on his person.
In the bedroom officers found three bags totaling 1.07 g methamphetamine, 5.99 g marijuana, a prescription bottle labeled with Jackson’s name, men’s clothing, a digital scale, sandwich bags, and a shoe containing 0.25 g heroin.
In the living room officers found approximately 1.33 g cocaine base, small amounts of methamphetamine, drug paraphernalia, cell phones (including one belonging to the female occupant), and men’s clothing in the living room closet.
Jackson made admissions to police that he sold crack cocaine and methamphetamine (and described drug-specific terminology and pricing), denied selling heroin, and told officers he had resided in the apartment for two months; an in-jail call corroborated that he flushed an item in the toilet.
No drug tax stamp was found on the methamphetamine; Jackson was charged with multiple drug offenses (each with habitual-offender enhancement) and convicted of lesser-included counts for some charges.

Issue	State's Argument	Jackson's Argument	Held
Sufficiency of evidence that Jackson constructively possessed cocaine base found in living room	Jackson’s admissions about selling crack, use of crack-specific terminology, residence in apartment, and other incriminating facts link him to the cocaine base	Aside from the meth on his person, State lacked proof Jackson possessed drugs found elsewhere in the apartment	Court: Evidence sufficient to support constructive possession of cocaine base
Sufficiency of evidence that Jackson constructively possessed marijuana found in bedroom/living room	Presence of marijuana in shared spaces, Jackson’s residence in apartment, his admissions, men’s clothing and personal pill bottle in bedroom, and incriminating conduct (bathroom flushing) link him to marijuana	Marijuana found in jointly-occupied premises not tied directly to Jackson; insufficient proof of control	Court: Evidence sufficient to support constructive possession of marijuana
Sufficiency of evidence for failure to possess required tax stamp (aggregate methamphetamine >7 g)	Jackson possessed 6.97 g on his person plus 1.07 g in bedroom attributable to him by constructive-possession evidence, yielding over 7 g taxable amount	Only 6.97 g was directly on Jackson; other meth in bedroom not proved to be his	Court: Sufficient evidence to find Jackson constructively possessed more than 7 g and thus violated tax-stamp statute

State v. Garr, 461 N.W.2d 171 (Iowa 1990) (standard for reviewing sufficiency of evidence and viewing evidence in light most favorable to the State)
State v. Lambert, 612 N.W.2d 810 (Iowa 2000) (standard of review for challenges to sufficiency of evidence)
State v. Reed, 875 N.W.2d 693 (Iowa 2016) (constructive-possession doctrine and need for additional proof when premises are jointly occupied)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (definition of constructive possession requiring knowledge and authority to control)
State v. Kern, 831 N.W.2d 149 (Iowa 2013) (factors to evaluate constructive possession in jointly occupied premises)
State v. Thomas, 847 N.W.2d 438 (Iowa 2014) (contrasting occupants’ conduct at police entry as probative of guilt)
State v. Henderson, 696 N.W.2d 5 (Iowa 2005) (one occupant’s incriminating acts can imply guilt when others do not)