State of Iowa v. Michael James Jones, 967 N.W.2d 336

Background:

On Dec. 27, 2016, Clay County Deputy Long found a Dodge Durango stopped on the shoulder and a second vehicle in a ditch; Michael Jones was at the scene and walked past the Durango as Long arrived.
Deputy Long observed a small black drawstring bag on the shoulder about 12–18 inches in front of the Durango’s passenger tire; dashcam showed Jones pass that exact spot and look back toward the ground.
Deputies opened the bag and found a glass meth pipe, seven individually wrapped baggies of methamphetamine (total ≈ 8.5 g), and a small amount of marijuana; additional meth was found inside a false battery.
Jones told deputies the bag was “probably nothing good” and later denied knowledge of it; officers seized two $100 bills and Jones’s license, and field tests of those items were positive for methamphetamine.
Jones was tried and convicted of possession of methamphetamine with intent to deliver and possession of marijuana; the court of appeals reversed on sufficiency grounds, and the Iowa Supreme Court granted further review.
The Supreme Court vacated the court of appeals decision and affirmed the district court, holding the jury’s verdict was supported by substantial evidence.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove possession (meth w/ intent; marijuana)	State: bag was found inches from Jones’s vehicle where he passed and looked back; bag appeared recently placed; Jones’s statement and meth on his money/license show knowledge and possession	Jones: he was merely present; someone else could have dropped/abandoned the bag	Affirmed conviction — viewed in State’s favor, evidence supports logical inferences of possession beyond a reasonable doubt
Whether "actual possession" requires finding the contraband on the person at time of arrest	State: actual possession includes past possession — item need not be on person at arrest if evidence shows it was on person at an earlier time	Court of appeals (per Jones’s position) treated this as only constructive possession because item was not found on Jones’s person	Court rejects CA’s narrow rule; actual possession can be established by evidence showing it was on the person at one time (Thomas, Vance)
Whether court of appeals correctly applied Schurman (circumstantial-evidence test) and barred stacking inferences	State: Schurman’s distinction is overruled; circumstantial and direct evidence are equally probative; stacking inferences permitted if reasonable (Ernst, O’Connell)	Court of appeals applied Schurman, required exclusion of all rational hypotheses and found impermissible stacking	Court holds CA erred: Schurman’s test and strict anti-stacking are not controlling; verdict may rest on reasonable inferences from circumstantial evidence

Key Cases Cited

State v. Thomas, 847 N.W.2d 438 (Iowa 2014) (actual possession may be proved by evidence showing item was on defendant at one time)
State v. Vance, 790 N.W.2d 775 (Iowa 2010) (supports finding of past actual possession even if not on person at arrest)
State v. O'Connell, 275 N.W.2d 197 (Iowa 1979) (overruled the strict direct-vs-circumstantial evidence distinction)
State v. Schurman, 205 N.W.2d 732 (Iowa 1973) (older circumstantial-evidence test requiring exclusion of all rational hypotheses; court explains it was overruled)
State v. Ernst, 954 N.W.2d 50 (Iowa 2021) (clarifies that stacking inferences is permissible if the inference is reasonable, and rejects Schurman’s framework)
State v. Tipton, 897 N.W.2d 653 (Iowa 2017) (standard for substantial-evidence review; defer to jury if evidence supports verdict)
State v. DeWitt, 811 N.W.2d 460 (Iowa 2012) (distinguishes fair inference of guilt from mere suspicion or speculation)
United States v. Cantrell, 530 F.3d 684 (8th Cir. 2008) (federal authority that actual possession is physical control at a given time)