United States v. Morales, 758 F.3d 1232

Morales, a convicted felon, was a passenger in a vehicle stopped by police; he immediately exited and fled on foot.
Deputy Hornback chased Morales about one block, lost sight of him briefly, then apprehended him; a loaded handgun was found in the yard along Morales’s flight path.
The recovered gun appeared clean (no dust, dirt, or moisture); a shell casing was found in the vehicle and a cell phone was found along the same path and later retained by Morales.
Morales was charged under 18 U.S.C. § 922(g)(1) (felon in possession); he was convicted by a jury and sentenced to 86 months.
On appeal Morales challenged (1) sufficiency of the evidence as to knowing possession, and (2) a due process claim that being handcuffed and transported through the courthouse (possibly visible to venire) prejudiced his trial.
The district court denied a new venire and the motion for judgment of acquittal; the Tenth Circuit reviewed sufficiency de novo and the handcuffing claim for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Morales knowingly possessed the firearm	Government: circumstantial evidence (flight, weapon found on flight path, condition of gun, phone found and retained by Morales) supports actual possession	Morales: no direct evidence he carried or dropped gun; no DNA/fingerprints; yard not under his control; verdict rests on piling inference upon inference	Court: Affirmed conviction — circumstantial evidence viewed collectively supports a reasonable juror finding Morales actually possessed the gun (actual possession)
Use of visible restraints (handcuffing) during transport through courthouse — due process	Morales: handcuffs in view of venire violated Fifth Amendment and entitles him to new trial; prejudicial even if brief	Government/Marshals: handcuffing was for security/escape-risk reasons; isolated view is not presumptively prejudicial; alternatives were inadequate	Court: No due process violation — defendant failed to show actual prejudice; even under Deck, handcuffing was justified by defendant-specific security/escape risk given his criminal history, so denial of new trial affirmed

United States v. Cardinas Garcia, 596 F.3d 788 (10th Cir. 2010) (standard for sufficiency review)
United States v. Colonna, 360 F.3d 1169 (10th Cir. 2004) (elements of § 922(g)(1))
United States v. McCane, 573 F.3d 1037 (10th Cir. 2009) (actual vs. constructive possession)
United States v. McCoy, 781 F.2d 168 (10th Cir. 1985) (possession may be proved by circumstantial evidence)
United States v. Fernandez, 18 F.3d 874 (10th Cir. 1994) (flight as circumstantial evidence of guilt)
United States v. Simpson, 950 F.2d 1519 (10th Cir. 1991) (isolated juror view of defendant in restraints insufficient for new trial absent actual prejudice)
Deck v. Missouri, 544 U.S. 622 (2005) (visible shackling violates due process unless justified by specific security interest)
United States v. Wardell, 591 F.3d 1279 (10th Cir. 2009) (defendant-specific security needs can justify visible restraints)
United States v. McKissick, 204 F.3d 1282 (10th Cir. 2000) (no presumption of prejudice where jurors may have glimpsed restraint)
United States v. Haynes, 729 F.3d 178 (2d Cir. 2013) (district court must make on-the-record defendant-specific shackling determinations)