United States v. Ridolfi, 2014 U.S. App. LEXIS 19047

In early morning Nov. 28, 2011, police encountered Corey Ridolfi in the driver's seat of a Ford Focus whose trunk was packed with items later identified as proceeds of multiple November burglaries, including two shotguns with serial numbers etched off.
Ridolfi and his cousin Jared Lemay matched a neighborhood caller’s description; Ridolfi gave an implausible account of his whereabouts and was nervous; neither had valid driver’s licenses and the car was registered to Lemay’s father.
Evidence connected trunk contents to three recent burglaries: the shotguns and women’s jewelry to an early-November Cumberland burglary; other sports memorabilia to a different burglary across the street from where the car was parked that night.
Ridolfi sold ten pieces of the stolen women’s jewelry at a Woonsocket pawnshop on Nov. 9 for $1,200; security video contradicted his explanations to police about that transaction.
At a Nov. 11 party, Lemay displayed one of the stolen shotguns; Ridolfi attended the party though it is not established whether he saw the display. Ridolfi was a convicted felon.
Ridolfi was charged and convicted by a jury of being a felon in possession of firearms (18 U.S.C. § 922(g)(1)) and knowingly possessing stolen firearms (18 U.S.C. §§ 2 & 922(j)); he appealed challenging sufficiency of evidence that he knowingly possessed the shotguns and knew they were stolen.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Ridolfi knowingly possessed the shotguns	Government: constructive possession established by Ridolfi’s dominion over the vehicle, involvement in selling burglary proceeds, presence near recent burglary, false statements, and shared access with Lemay	Ridolfi: no particularized evidence linking him to the guns — no proximity, access, movement toward, handling of, or statements about the firearms	The court affirmed: a rational jury could infer constructive (joint) possession from control of the car, participation in disposing of stolen goods, proximity to burglary scene, nervous/false statements, and relationship with Lemay.
Sufficiency of evidence that Ridolfi knew the shotguns were stolen	Government: pawnshop sale of identical jewelry and Lemay’s public display support knowledge or reasonable cause to believe guns were stolen	Ridolfi: (not argued on appeal in detail) challenged lack of direct proof he knew guns were stolen	The court affirmed: same inferences that supported constructive possession also supported finding Ridolfi knew or had reasonable cause to believe the guns were stolen.

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
United States v. McLean, 409 F.3d 492 (1st Cir. 2005) (constructive possession defined as control and intent to exercise dominion)
United States v. DeCologero, 530 F.3d 36 (1st Cir. 2008) (role in criminal enterprise supports inference of access and joint possession)
United States v. Rodríguez-Lozada, 558 F.3d 29 (1st Cir. 2009) (mere presence or association insufficient to prove knowledge/possession)
United States v. Valerio, 48 F.3d 58 (1st Cir. 1995) (warning against improper stacking of inferences in certain contexts)
United States v. Burgos, 703 F.3d 1 (1st Cir. 2012) (distinguishing contexts where piling inferences requires caution)