Johnson v. Mississippi
Annotate this CaseDefendant Alvin Johnson was convicted of possession of cocaine and sentenced to sixteen years' imprisonment with nine suspended and five years of post-release supervision and a fine. The Court of Appeals affirmed Defendant's conviction and sentence. Defendant petitioned the Supreme Court for a writ of certiorari concerning two issues: (1) whether the State presented sufficient evidence to sustain his conviction; and (2) whether the agents' search of a nearby vehicle violated Defendant's right to be free from unreasonable searches and seizures within the Fourth and Fourteenth Amendments to the United States Constitution and Sections 14 and 23 of the Mississippi Constitution. The Supreme Court granted Johnson’s certiorari petition, and found Defendant's first issue to be dispositive. The State failed to prove beyond a reasonable doubt that Johnson was in constructive possession of the cocaine found in the nearby vehicle. Therefore, the circuit court erred by denying Defendant's motion for judgment notwithstanding the verdict (JNOV). Finding that proximity alone was insufficient to show constructive possession, and that the State presented no additional incriminating circumstances, the Supreme Court reversed the Court of Appeals' judgment and that of the trial court and rendered judgment in Defendant's favor.
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