State v. Shockley, 557 S.W.3d 512

In Sept. 2014 Diangleo Shockley and his brother Antoine began renting a Perryville house; Shockley asked the landlord to install a lock on his bedroom door and kept it locked.
On Jan. 14, 2016 police executed a search warrant at the residence based on a tip about an illegally owned weapon; Antoine was home, Shockley was not.
Officers found Shockley’s bedroom locked, forced it open, and discovered three small bags of methamphetamine, marijuana paraphernalia (including pipes and a partially smoked cigarette), a digital scale, and a locked safe.
After obtaining a second warrant and opening the safe, officers found $8,070 in cash, paperwork addressed to both brothers, a prescription in Antoine’s name, and a handgun.
Shockley was charged and convicted by jury of: possession of methamphetamine with intent to distribute; unlawful possession of a firearm; unlawful use of a weapon; possession of marijuana; and possession of drug paraphernalia with intent to use.
Shockley appealed, arguing insufficiency of evidence as to each conviction; the court reviewed whether constructive possession was proven.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved constructive possession of items found in the locked bedroom and safe (supporting all convictions)	State: exclusive control over the locked bedroom supported inference Shockley constructively possessed the contraband and firearm	Shockley: presence of paperwork and a prescription in Antoine’s name shows lack of exclusive control and insufficient connection to the contraband	Court: Affirmed—evidence that Shockley requested and used a keyed lock, the room was locked and officers had to force entry, and the safe was in the locked room supported a reasonable juror’s finding of exclusive control and thus constructive possession

State v. Phillips, 477 S.W.3d 176 (Mo. App. E.D. 2015) (standard for reviewing sufficiency of the evidence)
State v. Moses, 265 S.W.3d 863 (Mo. App. E.D. 2008) (possession may be actual or constructive)
State v. Purlee, 839 S.W.2d 584 (Mo. banc 1992) (constructive possession requires access to and control over premises)
State v. Buford, 907 S.W.2d 316 (Mo. App. E.D. 1995) (exclusive control over premises supports an inference of possession)
State v. Morris, 41 S.W.3d 494 (Mo. App. E.D. 2000) (joint possession requires additional evidence linking defendant to contraband)
State v. Carouthers, 714 S.W.2d 867 (Mo. App. E.D. 1986) (exclusive control inference can stand despite other occupants’ presence)
State v. McCracken, 518 S.W.2d 229 (Mo. App. 1974) (safe in defendant’s room can be considered under defendant’s exclusive control despite others’ access)