State Of Washington v. Marvin Lawrence Meadows, 48373-4

Meadows, a felon, and his wife Charnell rented a Lakewood home; police obtained and executed a search warrant targeting a co-tenant.
Officers seized four firearms in the upstairs bedroom the couple shared: a .357 Magnum, a 12-gauge shotgun (loaded), an SKS rifle, and a .22 revolver; some guns were visible and readily accessible.
Meadows’s clothing and a utility bill in his name were found in the upstairs bedroom; he gave officers keys to the residence.
Charnell initially told police only the shotgun belonged to her, later claimed she bought multiple guns and hid them from Meadows, and testified the guns had been kept in a locked downstairs room before she moved them upstairs.
Trial court discredited Charnell’s testimony, found Meadows had dominion and control over the .357 and the shotgun, and convicted Meadows of two counts of first-degree unlawful possession of a firearm; acquitted on the SKS and .22 because they were not shown to be operable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove possession	State: constructive possession via dominion and control based on keys, clothes, bill, and accessibility of guns	Meadows: lacked knowledge and stayed in another room; wife owned guns and hid them	Court: Affirmed — substantial evidence supports findings of dominion and control and constructive possession
Credibility of wife’s testimony	State: inconsistencies and implausible claims undercut her story	Charnell/Meadows: her testimony exculpates Meadows (ownership, locked storage, destroyed receipts)	Court: Trial court’s credibility findings are controlling; court rejected Charnell’s account
Trial court failure to rule on State’s hearsay motion	State: hearsay inadmissible; court addressed issue at trial	Meadows: court erred by not ruling on motion to suppress hearsay	Court: No reversible error — record shows no ruling needed and no prejudicial hearsay ruling occurred
Ineffective assistance of counsel	Meadows: counsel failed to file a written suppression motion and mishandled video evidence	State: record does not support allegations; remedy is collateral relief if supported	Court: Denied on direct appeal; suggested PRP (personal restraint petition) if Meadows has further evidence

State v. Homan, 181 Wn.2d 102 (2014) (standard for sufficiency review after bench trial)
State v. Davis, 182 Wn.2d 222 (2014) (constructive possession requires dominion and control under totality of circumstances)
State v. Chavez, 138 Wn. App. 29 (2007) (circumstantial evidence may establish dominion and control)
State v. Cantabrana, 83 Wn. App. 204 (1996) (dominion over premises creates rebuttable inference of dominion over contraband)
State v. Prestegard, 108 Wn. App. 14 (2001) (credibility determinations for trier of fact are not revisited on appeal)
State v. McFarland, 127 Wn.2d 322 (1995) (ineffective assistance claims often raised by collateral attack)
State v. Grant, 196 Wn. App. 644 (2016) (preserving appellate-cost objections and procedure for cost bills)