United States v. Patrick Darrell Williams
708 F. App'x 570
| 11th Cir. | 2017Background
- Patrick Darrell Williams convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm.
- Evidence at trial included officers’ testimony about Williams’s statements inside a house, his actions at a car, and post-arrest inculpatory remarks.
- Prosecutor argued constructive possession based on Williams’s control/dominion over the car and his reference to the firearm as “his gun.”
- Williams moved for a jury instruction specifically addressing credibility of law enforcement witnesses; the district court denied the requested instruction.
- Williams appealed, arguing (1) insufficiency of the evidence and (2) abuse of discretion in refusing the requested credibility instruction.
- Eleventh Circuit reviewed sufficiency de novo and jury-instruction challenges for abuse of discretion, and affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove knowing possession of a firearm | Williams argued evidence was insufficient to prove he knowingly possessed the gun | Government argued officers’ testimony and Williams’s statements permitted inference of constructive/knowing possession | Affirmed — evidence sufficient; officers’ testimony was not incredible and statements supported constructive possession |
| District court refusal to give requested jury instruction on law-enforcement witness credibility | Williams argued the requested instruction was necessary and not adequately covered | Government argued existing credibility instruction and trial procedures (cross-exam, witness presentation) sufficiently addressed credibility | Affirmed — no abuse of discretion; requested instruction was substantially covered by instructions given |
Key Cases Cited
- United States v. Martin, 803 F.3d 581 (11th Cir. 2015) (standard for reviewing sufficiency of evidence)
- United States v. Thompson, 422 F.3d 1285 (11th Cir. 2005) (testimony is "incredible as a matter of law" only when impossible or unbelievable on its face)
- United States v. Gunn, 369 F.3d 1229 (11th Cir. 2004) (elements of § 922(g)(1) and possession may be actual or constructive)
- United States v. Hernandez, 433 F.3d 1328 (11th Cir. 2005) (constructive possession defined as ownership, dominion, or control over object or premises)
- United States v. House, 684 F.3d 1173 (11th Cir. 2012) (standard for abuse of discretion in refusing requested jury instructions)