United States v. William Rhodes
700 F. App'x 276
| 4th Cir. | 2017Background
- William Leon Rhodes was convicted by a jury of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).
- Officers found a Heritage revolver under a pillow in the master bedroom of Rhodes’s residence. Rhodes slept in that bedroom and testified he lived alone about 95% of the time.
- Rhodes argued he did not constructively possess the firearm; his stepson offered testimony favorable to Rhodes, but the jury rejected that testimony.
- The district court entered judgment on the conviction and revoked Rhodes’s supervised release based on the jury verdict.
- Rhodes appealed, arguing insufficient evidence supported the conviction and that revocation of supervised release was an abuse of discretion because it relied on an unsupported verdict.
Issues
| Issue | Plaintiff's Argument (Rhodes) | Defendant's Argument (U.S.) | Held |
|---|---|---|---|
| Sufficiency of evidence to prove constructive possession of firearm | Evidence insufficient; possession not proved, stepson testimony supports innocence | Firearm found in master bedroom under pillow where Rhodes slept; circumstantial evidence supports constructive possession | Affirmed — substantial evidence supports conviction |
| Whether firearm’s location supports inference Rhodes knew of and controlled it | Location insufficient to establish knowledge/control | Weapon was not well hidden and was under Rhodes’s pillow, allowing inference of awareness and immediate access | Affirmed — reasonable jury could infer knowledge/control |
| Credibility of defense witnesses (stepson) | Stepson’s testimony undermines prosecution’s theory | Credibility determinations are for the jury; conflicts do not require reversal | Affirmed — jury could disbelieve stepson |
| Revocation of supervised release based on the jury verdict | Revocation was abuse because verdict lacked support | Revocation relies on conviction; if conviction stands, revocation was within discretion | Affirmed — no abuse as verdict supported revocation |
Key Cases Cited
- United States v. Fuertes, 805 F.3d 485 (4th Cir.) (de novo review of denial of motion for judgment of acquittal)
- United States v. Engle, 676 F.3d 405 (4th Cir.) (definition and standard for "substantial evidence" in sufficiency review)
- United States v. Dinkins, 691 F.3d 358 (4th Cir.) (court may not resolve conflicts in evidence or judge witness credibility on sufficiency review)
- United States v. Herder, 594 F.3d 352 (4th Cir.) (elements and proof of constructive possession)
- United States v. Shorter, 328 F.3d 167 (4th Cir.) (inference of constructive possession from location of firearms in residence)
- United States v. Padgett, 788 F.3d 370 (4th Cir.) (standard of review for supervised-release revocation)