State of Minnesota v. Tommy Salyers, III, 858 N.W.2d 156

Salyers was convicted of being a felon in possession of a firearm, possession of a firearm with no serial number, and possession of a short-barreled shotgun, based on discovery of a locked gun safe with firearms during a 2012 search of his home.
Deputies used a crowbar to open the locked safe; inside were three firearms: a sawed-off shotgun (serial ground off), a full-length 20-gauge shotgun, and a .22 pistol, plus ammunition and unrelated items.
A key found in the bedroom fit the safe but would not turn the lock; a coffee mug near the safe contained a choke and ammunition that did not fit the guns found.
Salyers’ acquaintance, S.B., claimed ownership of the 20-gauge shotgun and the safe, and had recently lived in the home, but there was no evidence she owned the other firearms.
The court of appeals held there was sufficient evidence that Salyers constructively possessed the firearms based on a rule focusing on the container’s readily accessible contents under his control.
The Supreme Court granted review to decide the proper standard for constructive possession and whether the evidence supported conviction under Florine’s framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appellate rule on readiness of access complies with Florine	Salyers argues the rule improperly narrows Florine by focusing on accessibility.	Salyers' position is that Florine requires a broader, fact-driven analysis of dominion and control.	Florine framework must be used; not the readily accessible rule.
Sufficiency of evidence to prove constructive possession under Florine	State contends direct evidence of exclusive control over the safe proves possession.	Salyers argues insufficient link to knowledge and possession of contents.	Direct evidence of exclusive control over the place (the safe) supports constructive possession.
Standard of review for sufficiency in constructive-possession cases	State urges the circumstantial-evidence standard should apply where evidence is circumstantial.	Salyers argues Florine-based analysis is sufficient and circumstantial standard may be applicable depending on the facts.	Court applied Florine-based analysis and affirmed that the evidence supported possession without applying a heightened circumstantial standard.

State v. Florine, 303 Minn. 103 (1975) (constructive possession requires exclusive control or strong inferable dominion)
State v. Loyd, 321 N.W.2d 901 (Minn. 1982) (possession may be actual or constructive)
State v. Olson, 482 N.W.2d 212 (Minn. 1992) (balanced instruction on possession factors required)
State v. Flowers, 734 N.W.2d 239 (Minn. 2007) (jury instructions must not single out one inference of possession)
State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (circumstantial-evidence standard and reasonableness of inferences examined)
State v. Anderson, 789 N.W.2d 227 (Minn. 2010) (analysis of evidentiary circumstances in possession cases)
Comm’r of Revenue v. Fort, 479 N.W.2d 43 (Minn. 1992) (fact-driven approach to reasonable inferences in possession cases)