State of Minnesota v. Robert Joseph Engen, A15-1954

Officers executed a probation-related residence check at a Litchfield home on Nov. 13, 2014; occupants included Engen and his girlfriend S.F., who shared the upstairs bedroom.
Engen hid in an 8×10 crawl space off the bedroom; officers removed a Styrofoam "door" and found Engen about four feet from two cloth bags.
A light blue bag contained pipes with burnt residue; a dark bag contained glass pipes, two meth-smoking light bulbs, and a small amount of green leafy material.
BCA testing of one light bulb detected methamphetamine; S.F. told officers both bags belonged to Engen; Engen admitted he was hiding from police.
Engen was charged and convicted (bench trial) of fifth-degree possession of a controlled substance, possession of drug paraphernalia, and storing methamphetamine paraphernalia in the presence of a child; he appealed on sufficiency grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Engen knowingly possessed methamphetamine (constructive possession)	The State: proximity, exclusive access to upstairs, prior hiding, admission, S.F.’s statement, and positive meth test support constructive and actual knowledge	Engen: someone else (J.S. or S.F.) could have placed the dark bag in the crawl space; he might not have known about or recognized the residue	Affirmed. Circumstances (4-ft proximity, crawl space exclusive to Engen/S.F., pipes/bong nearby, admission, S.F.’s statement, and Engen smoked from the bulb earlier) support only the inference of knowing possession, including joint possession theory.
Whether a trace amount of methamphetamine is sufficient for fifth-degree possession	The State: statute covers a "mixture containing a controlled substance," no weight element required	Engen: (argued insufficiency based on amount)	Affirmed. A trace amount suffices under Minn. Stat. §152.025; BCA positive test supports conviction.

State v. Florine, 303 Minn. 103 (recognizes actual knowledge requirement for possession)
State v. Salyers, 858 N.W.2d 156 (defining exclusive control and constructive possession)
State v. Smith, 619 N.W.2d 766 (proximity as factor for constructive possession)
State v. Pratt, 813 N.W.2d 868 (standard for sufficiency review)
State v. Palmer, 803 N.W.2d 727 (bench-trial sufficiency standard equals jury standard)
State v. Silvernail, 831 N.W.2d 594 (two-step analysis for circumstantial-evidence convictions)
State v. Moore, 846 N.W.2d 83 (deferring to factfinder on credibility in circumstantial cases)
State v. Al-Naseer, 788 N.W.2d 469 (requiring consideration of rational alternative hypotheses)
State v. Taylor, 650 N.W.2d 190 (defendant must point to record evidence supporting an alternate rational theory)
State v. Denison, 607 N.W.2d 796 (joint constructive possession doctrine)
State v. Porte, 832 N.W.2d 303 (affirming guilt where joint possession is plausible)
State v. Ali, 775 N.W.2d 914 (awareness of possessing controlled substance can be inferred from context)
State v. Traxler, 583 N.W.2d 556 (trace amount of methamphetamine sufficient for fifth-degree possession)