United States v. Michael Parsons, 946 F.3d 1011

Michael Parsons, a convicted felon (2009 aggravated assault), absconded while on pretrial release in Tennessee and flew a small plane to Arapahoe Airport, Nebraska, in January 2017.
Parsons was arrested at the airport the next morning; the unlocked plane remained in a hangar for about two months with multiple people having access before it was searched under warrant.
On March 22, 2017, FBI agents found an AR-15–style rifle, three loaded 30‑round magazines, and ammunition in the plane; personal items bearing Parsons’ name were near the gun.
Recorded jail calls by Parsons referenced "gifts" or the "nation’s items" left in the plane that needed removal; Parsons admitted at trial the recovered gun looked like one he purchased from Matthew Lovan in 2008, and Lovan testified he sold Parsons that firearm.
Parsons was charged under 18 U.S.C. § 922(g)(1) (felon in possession); after trial he moved for judgment of acquittal under Rule 29 on sufficiency grounds (arguing lack of knowing possession), which the district court denied.
The Eighth Circuit reviewed sufficiency de novo and affirmed Parsons’ conviction, finding sufficient circumstantial evidence to support constructive/knowing possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Parsons "knowingly" possessed the firearm for § 922(g)(1)	Parsons: insufficient proof of knowledge or control because the plane was left unlocked and others had access; gun could have been placed by someone else	Government: circumstantial nexus — Parsons piloted the plane, items with his name near the gun, recorded calls about removing items, admission the gun resembled his purchase, and his status as an absconder support constructive/knowing possession	Affirmed — a reasonable jury could infer Parsons knowingly possessed the firearm; Rule 29 denial was not error

United States v. Morris, 723 F.3d 934 (8th Cir. 2013) (standard for reviewing sufficiency of the evidence de novo)
United States v. Wiest, 596 F.3d 906 (8th Cir. 2010) (reversal only when no reasonable jury could find elements beyond a reasonable doubt)
United States v. Montgomery, 701 F.3d 1218 (8th Cir. 2012) (elements of § 922(g) possession offense)
United States v. Maxwell, 363 F.3d 815 (8th Cir. 2004) (constructive possession requires dominion over premises or the firearm)
United States v. Garrett, 648 F.3d 618 (8th Cir. 2011) (actual and constructive possession distinctions)
United States v. Evans, 431 F.3d 342 (8th Cir. 2005) (government may rely on circumstantial evidence to establish nexus)
United States v. Smith, 508 F.3d 861 (8th Cir. 2007) (knowledge ordinarily proven through circumstantial evidence)
United States v. White, 816 F.3d 976 (8th Cir. 2016) (constructive possession can be established despite others having access when nexus exists)
United States v. Ojeda, 23 F.3d 1473 (8th Cir. 1994) (circumstantial proof of knowledge)
Rehaif v. United States, 139 S. Ct. 2191 (2019) (adds element that defendant knew his prohibited status; discussed but not raised by Parsons)