United States v. David Griffith
2015 U.S. App. LEXIS 8607
| 8th Cir. | 2015Background
- Griffith, a felon, was found with shotgun parts in the car he drove.
- Jury convicted Griffith under 18 U.S.C. § 922(g) for unlawful firearm possession.
- Burglary occurred on June 5, 2013; a neighbor identified Griffith and the car involved.
- Police traced the car via license plate and stopped Griffith about 20 minutes after the burglary.
- A shotgun receiver and TV were recovered from the car and later seized under a warrant.
- District court instructed that brief possession can support a conviction, and Griffith appeals on both possession instructions and sufficiency of knowledge evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence shows Griffith knowingly possessed the firearm. | Griffith argues the government failed to prove knowledge of the gun. | Griffith contends mere proximity is insufficient; knowledge was not shown. | Sufficient evidence supports knowledge; conviction affirmed. |
| Whether the possession instruction improperly lowered the burden by allowing brief possession as basis for conviction. | Griffith claims the instruction reduced the required certainty. | Government invites proper consideration of possession and knowledge in context. | No reversible error; instructions were proper in context. |
Key Cases Cited
- United States v. Lewis, 593 F.3d 765 (8th Cir. 2010) (district-court instruction discretion in crafting jury instructions)
- United States v. Stymiest, 581 F.3d 759 (8th Cir. 2009) (instructional-error review requires accurate law and effect on substantial rights)
- United States v. Patterson, 684 F.3d 794 (8th Cir. 2012) (juror should follow comprehensive instructions; view as whole)
- United States v. Chatmon, 742 F.3d 350 (8th Cir. 2014) (sufficiency of evidence for felon-in-possession; constructive possession requires nexus)
- United States v. Serrano-Lopez, 366 F.3d 628 (8th Cir. 2004) (sufficiency standard; evidence can support guilty verdict under reasonable-inference)
