State of Iowa v. Tremayne Latoine Thomas, 2014 Iowa Sup. LEXIS 58

Background

Police observed marijuana use through an apartment window and smelled marijuana upon the door opening; they knocked, announced, and entered.
Six people were in the front room; Thomas and Henderson retreated into the single bedroom; Thomas closed and resisted the bedroom door while officers forced entry.
On top of rows of Norvell’s purses near the door, officers found a clear bag containing four individually wrapped $5 marijuana units and four $50 crack rocks prepackaged for sale; no fingerprints were recovered.
Henderson (seen smoking earlier) and Norvell (apartment resident) denied knowledge of the drugs; a spoon with cocaine residue and small bags were found on the kitchen table near other occupants.
Thomas gave a false name and claimed he fled because of an outstanding warrant (which did not exist); he had $120 cash and was charged and convicted of possession with intent to deliver marijuana and crack, and interference; the court of appeals reversed the possession convictions for insufficient evidence; the Iowa Supreme Court granted further review.

Issues

Issue	State's Argument	Thomas's Argument	Held
Sufficiency of evidence to prove possession with intent (actual or constructive)	Evidence (drugs found where Thomas had been holding door, his resistance, misdirection/false name, $120 cash, exclusionary denials by others) permits a rational jury to infer Thomas exercised dominion and control or had recently possessed the drugs	Presence in a jointly occupied dwelling and proximity are insufficient; alternate occupants (Henderson, Norvell, others) were equally plausible possessors; inferences are speculative	Affirmed conviction: substantial evidence supported possession — proximity, furtive conduct, false statements, and evidentiary exclusions of others suffice
Application of constructive vs. actual possession doctrines	Constructive possession may be inferred from location + conduct; Vance allows actual-possession inference when evidence suggests the defendant had the item at some earlier time	The court should apply rigorous limits on constructive-possession in joint-occupancy cases to avoid speculation	Court applied precedent (including Vance) to permit inference of actual/constructive possession here
Batson challenge to peremptory strike of sole minority alternate juror	Prosecutor proffered race-neutral reason: the juror emphatically disbelieved police credibility	Thomas argued the strike was racially motivated	Court upheld trial court: prosecutor gave a race-neutral reason and trial court credibility finding entitled to deference
Harmlessness / procedural posture of challenges not reached	State alternatively argued any Batson error would be harmless since alternate never seated; court did not decide	—	Court did not reach harmlessness argument; rejected Batson claim on its merits

Key Cases Cited

State v. Kern, 881 N.W.2d 149 (Iowa 2018) (when premises are jointly occupied additional links are required to infer possession)
State v. DeWitt, 811 N.W.2d 460 (Iowa 2012) (totality of circumstantial evidence can support possession even without exclusive ownership)
State v. Vance, 790 N.W.2d 775 (Iowa 2010) (actual possession may be inferred if substantial evidence shows the item was on defendant at one time)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (proximity, furtive movements, and ownership of similar items can support constructive possession)
State v. Carter, 696 N.W.2d 31 (Iowa 2005) (driver’s evasive movements and proximity to drugs supported an inference of possession)
State v. Nitcher, 720 N.W.2d 547 (Iowa 2006) (forensic links like fingerprints and manufacturing residue can establish possession)
State v. Webb, 648 N.W.2d 72 (Iowa 2002) (mere presence in a shared residence and proximity do not establish dominion and control)
State v. Cashen, 666 N.W.2d 566 (Iowa 2003) (conviction reversed where multiple occupants were equally proximate to contraband)
Batson v. Kentucky, 476 U.S. 79 (1986) (peremptory challenges based on race violate Equal Protection)