State v. Allen, 101 So. 3d 41

Defendant was convicted of possession of a firearm by a convicted felon, possession of cocaine, and possession of hydrocodone; the Court of Appeal vacated only the firearm conviction and affirmed the other two.
The Court of Appeal found an irresistible inference of possession of cocaine and hydrocodone from drugs found in separate locations: plastic bag on the floorboard, and pills in the rear of a patrol vehicle and at a residence.
For the handgun, the Court of Appeal held there was little to infer knowledge by defendant due to the location under the backseat where the child was seated and the vehicle ownership/possession questions.
Officer testimony showed the back window was tinted, the officer observed defendant reach toward the back seat, and a gun was found under the cushion during search of the vehicle after consent.
A drug-detection dog allegedly alerted to locations including the car area where cocaine was found and where the gun was concealed.
The Supreme Court reinstated the gun conviction, holding the evidence supported dominion and knowledge sufficient for possession, and affirmed the cocaine and hydrocodone convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of gun-possession evidence	State	Defendant	Conviction reinstated; sufficient evidence.
Sufficiency of cocaine/hydrocodone possession evidence	State	Defendant	Convictions affirmed.

State v. Calloway, 1 So.3d 417 (La. 2009) (limits on reviewing court substituting its view of evidence for fact-finder)
State v. Mussall, 523 So.2d 1305 (La. 1988) (due process limits on fact-finder deference)
State v. Major, 888 So.2d 798 (La. 2004) (dominion and control over controlled substances as basis for possession)
State v. Allen, 79 So.3d 1220 (La. App. 8th Cir. 2011) (drug-detection dog alerts support inferences of possession)