State of Tennessee v. Bobby Lee Robinson, 400 S.W.3d 529

Robinson indicted in 2007 for possession with intent to sell 300+ grams of cocaine, possession of marijuana, and paraphernalia after a police takedown of three men.
Cocaine and marijuana found in Grimes’ truck (within reach of Robinson) and in Grimes’ residence; total cocaine weight later at issue.
State charged 300+ grams by aggregating truck and residence weights; Robinson convicted of possession with intent to sell 300+ grams and paraphernalia.
Appellate court affirmed; Supreme Court granted permission to appeal on sufficiency of the evidence as to constructive possession.
Court held sufficient evidence to convict for possession in the truck (Class B), but insufficient evidence to prove constructive possession of cocaine or paraphernalia in Grimes’ residence; conviction reduced to 26–299 grams (Class B) and paraphernalia conviction vacated; remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is sufficient evidence of constructive possession for the Grimes’ residence drugs	Robinson: no direct link to residence; mere association insufficient	State: evidence shows knowledge and control via presence and statements	Insufficient evidence for constructive possession of residence drugs
Whether evidence supports constructive possession of drugs in Grimes’ truck	Robinson had knowledge or control due to proximity and statements	State: proximity and conduct establish dominion	Sufficient evidence to support constructive possession in the truck
Whether aggregate weighing to 300+ grams supports the Class A conviction	Weight combined supports 300+ grams	Conviction should reflect only weight in truck (26–299 g)	Conviction for 300+ g reduced to 26–299 g; Class A upheld then vacated by reduction
Whether the State’s lack of physical linkage to residence undermines conviction	Voice identification and travel with Grimes suffices	No physical evidence tying Robinson to residence	Insufficient link to residence; conviction vacated for paraphernalia; remand for resentencing
Whether paraphernalia conviction can stand given insufficiency regarding residence	Paraphernalia seized with other contraband; connected to defendant	No evidence tying Robinson to paraphernalia	Paraphernalia conviction vacated

State v. Shaw, 37 S.W.3d 900 (Tenn. 2001) (defines constructive possession and proximity rules)
State v. Patterson, 966 S.W.2d 435 (Tenn. Crim. App. 1997) (reiterates dominion and control standard for constructive possession)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (affirms circumstantial-evidence sufficiency standard)
State v. Cabbage, 571 S.W.2d 832 (Tenn. 1978) (jury credibility and evidentiary weight considerations)
United States v. Scofield, 433 F.3d 580 (8th Cir. 2006) (constructive possession requires more than presence; link to drugs must be shown)