United States v. Ronald White, Jr., 915 F.3d 1195

Defendant Ronald F. White, Jr. convicted after a bench trial for possession of an unregistered firearm (Street Sweeper 12‑gauge shotgun) in violation of 26 U.S.C. §§ 5841, 5861(d), 5871; sentence 46 months plus three years supervised release.
Firearm found inside a duffel bag in a closet of a bedroom at his parents’ home; White sometimes stayed in that bedroom.
The duffel also contained an Amtrak ticket in White’s name and a revolver with White’s DNA.
The Street Sweeper’s bore diameter (.729–.752 inches) makes it a “firearm”/destructive device under the National Firearms Act (NFA).
On appeal White challenged: (1) insufficient evidence of constructive possession; and (2) insufficient proof he knew the shotgun’s bore exceeded one‑half inch.
The Eighth Circuit affirmed, applying the circumstantial‑evidence standard for bench trials and inferring both constructive possession and knowledge from nexus and physical evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports constructive possession of the shotgun	Government: duffel in White’s bedroom closet contained his train ticket and a revolver with his DNA; he had access/control over bag and closet	White: at most constructive possession of the bag, not proof he knew the bag contained the shotgun or when it was placed there	Affirmed: sufficient circumstantial nexus (location, personal items, revolver with DNA) to infer constructive possession
Whether White knew the shotgun’s bore exceeded 1/2 inch (element of NFA offense)	Government: shotgun admitted into evidence and testimony established bore > 1/2 inch; knowledge can be inferred from external characteristics	White: no direct evidence he saw/handled the Street Sweeper or knew 12‑gauge bore size	Affirmed: court may infer requisite knowledge from condition/testimony and admitted weapon; sufficient circumstantial proof

United States v. White, 863 F.3d 784 (8th Cir. 2017) (defines NFA knowledge element and remand history)
Staples v. United States, 511 U.S. 600 (1994) (knowledge of weapon characteristics may be inferred from external indications)
United States v. Pace, 922 F.2d 451 (8th Cir. 1990) (insufficiency where defendant did not open/examine luggage containing contraband)
United States v. Patton, 899 F.3d 560 (8th Cir. 2018) (sufficiency review is fact‑intensive; review standard for bench trials)
United States v. Hutchins, [citation="292 F. App'x 842"] (11th Cir. 2008) (testimony about weapon dimensions and admission into evidence can support inference defendant knew physical characteristics)