United States v. Johnny Chatmon
2014 U.S. App. LEXIS 2158
| 8th Cir. | 2014Background
- Chatmon was convicted of unlawful possession of a firearm by a previously convicted felon under 18 U.S.C. § 922(g)(1) after a jury trial.
- Officers stopped Chatmon’s rental vehicle when it lacked functioning headlights; Chatmon was driver and sole occupant as the vehicle was pulled over.
- Rental records showed Williams, Chatmon’s mother, as the authorized driver; Chatmon had no ownership of firearms and Williams testified no firearm belonged to her.
- During inventory, officers found a firearm hidden in a loose center-console tray; additional items in the car included Chatmon’s textbooks and electrical equipment.
- Chatmon was arrested and claimed he was walking, not driving, conflicting with officer testimony that he was moving inside the car before the stop.
- At trial the Government argued Chatmon knowingly possessed the firearm; Chatmon appealed, challenging sufficiency of evidence and the district court’s rejection of a theory-of-defense instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove knowing possession | Chatmon (prosecution) contends the evidence supports knowing possession. | Chatmon contends insufficient evidence of knowledge to possess the firearm. | Sufficient evidence supported knowing possession |
| Adequacy of jury instruction on mere presence | Chatmon argues for a mere presence instruction to negate knowledge. | Government argues existing instructions already covered possession and knowledge. | District court did not abuse discretion; no need for mere presence instruction |
Key Cases Cited
- United States v. Garrett, 648 F.3d 618 (8th Cir. 2011) (elements of 922(g) possession and interstate commerce)
- United States v. Evans, 431 F.3d 342 (8th Cir. 2005) (constructive possession requires nexus to the defendant)
- United States v. Tindall, 455 F.3d 885 (8th Cir. 2006) (driver/sole occupant supports constructive possession)
- United States v. Hiebert, 30 F.3d 1005 (8th Cir. 1994) (constructive possession when defendant drove vehicle)
- United States v. Maloney, 466 F.3d 663 (8th Cir. 2006) (driver’s movements can support inference of concealment)
- United States v. Walker, 393 F.3d 842 (8th Cir. 2005) (false exculpatory statements admissible to show guilt)
- United States v. Penn, 974 F.2d 1026 (8th Cir. 1992) (false exculpatory statements as substantive evidence)
- United States v. Cantrell, 530 F.3d 684 (8th Cir. 2008) (mere presence instruction not required when adequately covered)
- United States v. Serrano-Lopez, 366 F.3d 628 (8th Cir. 2004) (cantrell line of reasoning on jury instructions)
- United States v. Lam, 338 F.3d 868 (8th Cir. 2003) (entire body of evidence suffices if strongly supports guilt)