United States v. Rickie Bellamy, Jr., 682 F. App'x 447

In May 2015 ATF agents executed a search warrant at a Detroit home; they encountered Rickie Bellamy, Jr. upstairs and later seized a firearm, ammunition, marijuana (some in vials labeled with Bellamy’s name and medical card number), marijuana packaging, a digital scale, and proof of residence from a bedroom.
A recorded interview played at trial contained Bellamy telling an agent that marijuana and a loaded firearm would be found in his room; agents also testified Bellamy identified the room as his, had a padlock on the door, and asked officers to lock it when they left.
Bellamy admitted possession of the marijuana and scale, claimed regular medically-motivated marijuana use, said the gun belonged to his father, and testified he usually slept on a couch and not in the seized bedroom.
Defense counsel sought to admit photographs taken the morning of Bellamy’s testimony showing the bedroom door without a padlock; the district court excluded them for Rule 16 noncompliance and as not probative, but allowed preservation for appeal.
The jury acquitted Bellamy on drug-possession and §924(c) counts but convicted him under 18 U.S.C. § 922(g)(3) (unlawful user of a controlled substance in possession of a firearm); the district court sentenced him to three years’ probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict under 18 U.S.C. § 922(g)(3) (unlawful user)	Government: record includes defendant’s admissions, recovered firearm in his room, items showing control of the premises and repeated marijuana use	Bellamy: held a Michigan medical marijuana card, so was a lawful user; no proof of addiction or unlawful use; federal statute shouldn’t preempt state MMMA	Affirmed. Court found evidence of repeated use and control of the premises; federal law treats marijuana as Schedule I and medical-card status does not render federal § 922(g)(3) inapplicable.
Exclusion of post-trial photographs (due process/right to present a defense)	Government: photos untimely under Rule 16, not probative, cumulative	Bellamy: photos rebut agents’ testimony about a padlocked door and were material to possession/dominion issue	Affirmed. Exclusion not an abuse of discretion or constitutional violation because photos were cumulative of Bellamy’s testimony and not likely to change the outcome given other evidence (his recorded admissions and proof of dominion).

Wilson v. Lynch, 835 F.3d 1083 (9th Cir. 2016) (medical-marijuana-card holders remain unlawful users under federal law)
Shalala v. Guernsey Mem'l Hosp., 514 U.S. 87 (1995) (interpretive rules advise public of an agency's construction of statutes it administers)
Holmes v. South Carolina, 547 U.S. 319 (2006) (limits on presenting defense evidence that is only marginally relevant)
Crane v. Kentucky, 476 U.S. 682 (1986) (defendant’s right to present a defense is not unfettered and subject to evidentiary rules)
United States v. Bailey, 553 F.3d 940 (6th Cir. 2009) (possession may be proven by dominion and control evidence)
United States v. Valenzuela-Bernal, 458 U.S. 858 (1982) (evidence is material if suppression might have affected the outcome)