Statute Annotations › Federal › 18 U.S.C. § 922

18 U.S.C. § 922

Unlawful acts involving firearms: the cases that interpreted this section

Jurisdiction
Federal
Case notes
8,290
Cited in passing
29,242
Citing cases indexed
49,010
Case dates
1970–2026
Screened through
2026-06-29
Checked for later law changes
2026-10-19
Courts' treatment: partly invalid
A reviewed case holds part of this section invalid or unenforceable. The Supreme Court’s invalidity rulings concerned the former school-zone offense in United States v. Lopez (1995) and the interim local-officer background-check duty in Printz v. United States (1997). Congress rewrote subsection (q), and the interim duties of subsection (s) expired in 1998.
More on this status

The Fifth Circuit reversed the district court’s ruling against §§ 922(a)(3) and (b)(3) in Mance v. Sessions (2018) and vacated its injunction. The Third Circuit reversed the as-applied ruling in Holloway v. Sessions (2018), holding in Holloway v. Attorney General (2020) that the plaintiff’s repeat high-BAC DUI was a serious crime and that § 922(g)(1) could constitutionally disarm him. The Fourth Circuit vacated its 2021 Hirschfeld ruling against the dealer handgun-sales restrictions after the case became moot. The Third Circuit later reversed the district court’s ruling against Range and held that § 922(g)(1) could not constitutionally disarm him on the facts of his nonviolent food-stamp misdemeanor. The Fifth Circuit held §§ 922(b)(1) and (c)(1) facially unconstitutional for dealer handgun sales to adults aged eighteen to twenty in Reese v. ATF (2025), reversing the district court. The Fourth Circuit later upheld § 922(b)(1) in McCoy v. ATF (2025), creating a circuit conflict over that subsection; its decision did not decide § 922(c)(1). The Supreme Court held in United States v. Hemani (2026) that subsection (g)(3) could not be applied to a regular marijuana user on the theory that regular use alone justified disarmament.

This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

37,532 citing cases reviewed of 49,010 in the citation index: 8,290 interpreted the section (annotated below), 29,242 cited it only in passing. Cases filed after 2026-06-29 may not have been reviewed yet.

Have a situation under 18 U.S.C. § 922?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Knowing possession

Section 922(g)(1) requires proof that the defendant knowingly possessed the firearm or ammunition.

United States v. Nicholas · filed 2017-04-24(g)(1)

To obtain a conviction under § 922(g)(1), the government must prove that Nicholas knowingly possessed the firearms and ammunition found in Henry’s truck.
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Section 922(g)(1) allows knowing possession of a firearm to be proved by circumstantial evidence showing more than mere proximity to the gun.

United States v. Gaines · filed 2017-06-23(g)(1)

But one officer did testify he saw Gaines “make a motion toward the rear of the vehicle toward his waist” and duck out of sight, and then the officer heard “a metal on pavement sound” before discovering the firearm underneath the car next to where Gaines had stood. This is sufficient circumstantial evidence to support Gaines’s conviction.
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Evidence of a felon’s belongings near a firearm and DNA on it can support a finding of knowing possession under § 922(g)(1).

United States v. Moore · filed 2017-10-24(g)(1)

A reasonable trier of fact could have concluded from this evidence that Moore knowingly possessed the firearm.
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Section 922(g)(1) requires knowing possession of a firearm; evidence beyond mere proximity to the gun can establish that element.

United States v. Roark · filed 2018-02-09(g)(1)

This evidence established more than Roark’s mere proximity to the weapon, see United States v. Griffith, 786 F.3d 1098, 1103 (8th Cir. 2015), and is sufficient for the jury to conclude that he knowingly possessed the gun, see United States v. Garrett, 648 F.3d 618, 622-23 (8th Cir. 2011).
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Section 922(g)(1) requires proof that the defendant knowingly possessed a firearm, which eyewitness testimony can establish.

United States v. Mitchell · filed 2018-03-19(g)(1)

We find to be singularly unpersuasive Mitchell’s contention that the evidence was insufficient to show that he had knowingly possessed a firearm. Five witnesses testified that Mitchell possessed a firearm. ... In a word, then, the evidence was sufficient to establish that Mitchell had knowingly possessed a firearm.
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Section 922(g)(1)’s knowing-possession element can be proved by testimony identifying the defendant as a passenger who had a gun and threw an object where police recovered one.

United States v. Williams · filed 2018-04-10(g)(1)

But viewing the evidence in the light most favorable to the government and the jury’s verdict, the testimony at trial established (1) that the front-seat passenger had a gun, (2) that the front-seat passenger threw an object out of the vehicle, (3) that police recovered a gun in the area where the object was thrown, and (4) that Williams was the front-seat passenger. This evidence, taken together, was sufficient for a jury to conclude that Williams had knowing possession of the firearm.
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For § 922(g), a defendant’s proximity to a firearm and statements acknowledging ownership can establish knowing possession.

United States v. Kennedy · filed 2018-08-17(g)

In this case, there was substantial circumstantial evidence demonstrating Kennedy’s knowing possession of a firearm. Kennedy was in a vehicle in which police found a handgun on the right side of the driver’s-side footwell, within reach of Kennedy in the front passenger seat. And beyond this proximity, Kennedy’s own recorded statements and answers to questions from law enforcement—including that the handgun was “[o]f course” his—unequivocally demonstrated that the handgun belonged to him.
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Section 922(g)(1)’s knowing possession element can be proved by evidence that a defendant picked up a gun and carried it briefly while knowing it was a gun.

United States v. Witherall · filed 2018-08-23(g)(1)

Officer Nienhuis’s testimony, particularly when taken together with the WatchGuard video and the testimony of Mitch Hoff, was enough for a rational juror to infer that Witherall picked a pistol up off the ground and ran with it for a short distance, and that he knew it was a gun when he picked it up.
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Section 922(g)(1)'s knowing-possession element may be proved by testimony that the defendant handled a matching gun and evidence linking him to where the gun was found.

United States v. Wilson · filed 2018-09-28(g)(1)

Viewed in the light most favorable to the government, the evidence presented at trial was sufficient to permit a reasonable factfinder to conclude ... beyond a reasonable doubt that Wilson possessed knowingly the gun found in the bedroom. Three witnesses testified expressly that they had each seen Wilson with a gun matching the description of the gun charged in the indictment. The gun was found in plain view in the bedroom in which Wilson was located when police executed the search warrant.
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Section 922(g)(1) allows knowing possession of a firearm to be proved by circumstantial evidence, including control of a vehicle and a firearm in plain view near the driver’s seat.

United States v. Bridgeforth · filed 2019-06-03(g)(1)

To convict Bridgeforth under § 922(g), the government needed to prove three elements: (1) that Bridgeforth had a previous conviction punishable by a term of imprisonment exceeding one year, (2) that he knowingly possessed the firearm found in the car, and (3) that the firearm had traveled in or affected interstate commerce. ... However, Bridgeforth controlled the car just before discovery of the firearm and was the sole occupant at the time. Shahan found the firearm on the driver’s side, in plain view near the seat. ... Accordingly, we find there was sufficient circumstantial evidence to sustain Bridgeforth’s conviction.
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Section 922(g)(1)’s knowing possession element is satisfied by brief possession of a firearm; self-defense or duress does not negate that element.

United States v. Ortiz · filed 2019-06-19(g)(1)

Parker and Hammond compel the conclusion that Ortiz satisfied the knowing possession element when he grabbed the gun and ran with it. Whether he did so under duress or in self-defense does not negate this offense element.
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Section 922(g)(1)’s knowing-possession element can be proved by testimony that a firearm fell from the defendant’s waist.

United States v. Watkins Brown · filed 2019-07-26(g)(1)

Officer Montgomery testified he saw “a black revolver c[o]me out of [Brown’s] waist” and “land[] on his side.” Based on this testimony, a rational trier of fact could find Brown knowingly possessed the firearm.
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Section 922(g) bars a convicted felon from possessing a firearm, and proof of knowing possession can support a conviction.

United States v. Phay Lam Souphanthog · filed 2019-10-31(g)

Accordingly, we hold that there was sufficient evidence to support the jury’s determination that Souphanthog knowingly possessed the firearms in Counts Two and Three.
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Section 922(g)(1)’s knowing-possession element can be satisfied by circumstantial evidence showing a sufficient connection between the defendant and the firearm.

United States v. Parsons · filed 2020-01-07(g)(1)

Taken together, there was sufficient evidence to establish a nexus between Parsons and the gun. The district court did not err in denying Parson’s Rule 29 motion for judgment of acquittal.
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Section 922(g)(1)'s knowledge element is satisfied when a convicted felon knowingly possesses a firearm or ammunition.

High Wolf v. United States · filed 2020-01-27(g)(1)

His conduct satisfied the knowingly element of § 922(g)(1).
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Section 922(g)(1)’s knowing-possession element can be supported by eyewitness testimony that the defendant hid a firearm under a car seat.

United States v. Gates · filed 2020-02-05(g)(1)

In light of the testimony of the sole witness that he saw Gates stuffing the firearm under the front passenger seat of the vehicle, the jury’s finding that Gates was a felon who knowingly possessed a firearm withstands scrutiny.
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Section 922(g)(1) requires proof that a convicted felon knowingly possessed a firearm, which may be shown by circumstantial evidence.

United States v. Ellis · filed 2020-02-25(g)(1)

The jury was entitled to infer from that circumstantial evidence that Ellis possessed the .38 caliber revolver.
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Section 922(g)(1) requires knowing possession of a firearm; proximity to it alone is insufficient.

United States v. Warren Franklin, Jr. · filed 2020-06-03(g)(1)

The instructions on the firearms offenses required proof that Franklin “knowingly possessed a firearm.” Id. at 26-27 (emphasis added). The jury thus could not convict based solely on Franklin’s proximity to the gun and drugs; they were required to find that Franklin knew that the items were in the backpack.
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Section 922(g)(1)'s knowing-possession element can be satisfied by circumstantial evidence of constructive possession of a firearm.

United States v. Morgan · filed 2020-09-04(g)(1)

When viewed in the requisite light most favorable to the Government, the evidence provided a substantial basis for a reasonable juror to determine beyond a reasonable doubt that Morgan acted knowingly in constructively ... possessing both the methamphetamine and the firearm hidden in the vehicle he was driving.
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A jury may infer a felon's knowing possession of a firearm found in the back seat of a pickup registered to and driven by him.

United States v. Gonzalez · filed 1998-12-16(g)(1)

Hipolito was driving a pickup registered in his name with a gun in the back seat during a drug smuggling trip. The jury was entitled to conclude that Hipolito knew the gun was there.
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A jury may infer that a felon knew a firearm was in his possession when he drove his own pickup with the gun in the back seat.

United States v. Hipolito Gonzalez, Jr., Abelardo Gerardo Gonzalez, and Alberto Javier Gonzalez · filed 1999-01-26(g)(1)

Hipólito was driving a pickup registered in his name with a gun in the back seat during a drug smuggling trip. The jury was entitled to conclude that Hipóli-to knew the gun was there.
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Section 922(g)(1) requires knowing possession of a firearm by a convicted felon.

United States v. Merwin Smith · filed 2020-10-26(g)(1)

“Knowing possession” is an element of 18 U.S.C. § 922(g)(1), and previous possessions are relevant to proving this element.
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Section 922(g)(1)’s knowing-possession element can be proved by testimony that the defendant displayed a firearm and that one was later found in his apartment.

United States v. Perez · filed 2021-01-25(g)(1)

Here, the record contains sufficient evidence that a reasonable factfinder could have found that Perez knowingly possessed a firearm beyond a reasonable doubt. Two witnesses testified that Perez threatened to kill Hernandez’s guest and lifted up his shirt to reveal a firearm and that a firearm was later found in Perez’s apartment.
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Section 922(g)(1) requires proof that the defendant knowingly possessed a firearm; recorded remarks about the gun can establish that knowledge.

United States v. Brady Rogers · filed 2021-02-04(g)(1)

The jury saw the shotgun seized from Rogers’ truck and heard the patrol vehicle recording of Rogers’ conversation with Rice about the gun. The evidence, when viewed in the light most favorable to the verdict, was sufficient to prove beyond a reasonable doubt that Rogers knew about the shotgun and knew about its “sawed-off” nature – that is, it had a barrel less than 18 inches.
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Section 922(g)(1)’s knowing possession element can be proved by evidence that a defendant knowingly threw a bag containing a firearm from a vehicle.

United States v. Webb · filed 2021-04-07(g)(1)

Webb’s admission that he knowingly threw the bag containing the shotgun from the vehicle, which was corroborated by the arresting officer’s testimony, is substantial evidence that he possessed the firearm.
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Section 922(g)(1) requires the government to prove that the defendant knowingly possessed the firearm, even if he stipulates to knowing his felony status.

United States v. Perpall · filed 2021-05-18(g)(1)

But Perpall’s stipulation ... that he knew he was a convicted felon does no work here. That stipulation did not speak to whether he knowingly possessed a firearm.
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Section 922(g)(1) requires proof that the defendant knowingly possessed a firearm; eyewitness testimony and corroborating evidence can establish possession.

United States v. Caliph Barr · filed 2021-07-12(g)(1)

Under this standard, the evidence at trial was sufficient for a rational juror to find beyond a reasonable doubt that Barr knew he possessed a firearm.
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Eyewitness testimony corroborated by phone records and shell casings can establish knowing possession of ammunition under § 922(g)(1).

United States v. Hill · filed 2021-07-21(g)(1)

To convict a defendant under § 922(g)(1), the government must prove that (1) the defendant had previously been convicted of a felony; (2) he thereafter knowingly possessed a firearm or ammunition; (3) he knew he was a convicted felon when he possessed the firearm or ammunition; and (4) the possession was in or affecting interstate commerce. ... This evidence, together with the forensic and investigative testimony about the shell casings, was sufficient to support Mr. Hill’s conviction.
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Section 922(g)(1)’s knowing-possession element can be proved through eyewitness testimony and circumstantial evidence even when no fingerprints are found on the firearm.

United States v. Henderson · filed 2021-08-27(g)(1)

A jury convicted Isaiah Henderson of being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). ... However, no one else was in the store at 2:30 a.m., Obert found the firearm almost immediately after Henderson left, Nimmers testified the gun she saw was black, and the revolver in the bathroom had black electrical tape around its handle. “The absence of corroborating physical evidence,” such as fingerprints on the firearm, “is not a sufficient basis for us to conclude the jury acted unreasonably.” ... For these reasons, the court did not err in denying Henderson’s motion for acquittal or a new trial based on insufficiency of the evidence.
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Section 922(g)(1) requires proof that the defendant knew he possessed a firearm.

Delgado v. United States · filed 2021-11-12(g)(1)

To prove a violation of § 922(g)(1), the government “must show that the defendant knew he possessed a firearm.”
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Section 922(g)(1)’s knowing-possession element can be satisfied by evidence that a firearm was within the defendant’s immediate reach or control and that he knew it was there.

Mitchell v. United States · filed 2022-01-04(g)(1)

This evidence was sufficient to allow a reasonable trier of fact to conclude, beyond a reasonable doubt, that Petitioner knowingly possessed the firearm. ... The gun being on the dashboard, the jury reasonably could have found that Petitioner had the ... gun within his immediate reach or control and that he knew about its presence.
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Section 922(g)(1)’s knowing-possession element can be satisfied by evidence that the defendant retrieved, fired, and brought home the firearm.

United States v. Perkins · filed 2022-02-18(g)(1)

A reasonable jury could thus conclude that Perkins had actual possession of that firearm, at a minimum, when he retrieved it from his father’s house, fired it, and brought it home on December 19.
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Section 922(g)(1)’s knowing-possession element can be established by dominion and control over the area where firearms are found.

United States v. Justin · filed 2022-06-15(g)(1)

Even absent Justin’s confession, his dominion and control over the area where the firearms were found is sufficient to establish that he knowingly possessed them.
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Section 922(g)(1) prohibits a felon from knowingly possessing a firearm even when he intends to return it to its owner.

Johnson v. United States · filed 2022-07-07(g)(1)

Even accepting Johnson’s narrative—that his friend inadvertently left the gun in his car, and that Johnson retrieved the gun and placed it on his person minutes before officers arrived in order to return it to his friend—his actions would still constitute a violation of § 922(g)(1): he still knowingly possessed the firearm when he placed it on his person. His alleged reasons for possessing the firearm are not a defense to the charge of being a felon in possession of a firearm.
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A § 922(g)(1) conviction may rest on evidence sufficient for a reasonable jury to find that the defendant knowingly possessed a firearm.

United States v. McKee · filed 2022-08-02(g)(1)

Based on this evidence, a reasonable jury could have found that McKee knowingly possessed the firearm found in Apartment H6 on August 30th. Thus, we find the evidence sufficient to sustain McKee’s conviction.
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Section 922(g)(1)’s knowing-possession element can be supported by testimony that the defendant admitted the firearm was his and that he kept it for protection.

United States v. Kenneth Carlyle, Jr. · filed 2022-08-11(g)(1)

We have reviewed the record and conclude the evidence was sufficient to support the jury’s finding that Carlyle knowingly possessed the firearm that was found by police officers under the driver’s seat of the vehicle that Carlyle was driving. The officers testified that Carlyle admitted that the vehicle and firearm were his, that he got the firearm from his cousin, and that he kept it for protection.
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Section 922(g) requires knowing possession of a firearm, which a jury may infer from finding a gun under the driver’s seat of the defendant’s car.

United States v. Marquis Antonio Tompkins · filed 2023-01-19(g)

The officers’ discovery of the gun under the driver’s seat of Tompkins’s car, which was parked at the mall where Tompkins had just been shot, supported the jury’s reasonable inference that Tompkins knowingly possessed the firearm.
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Section 922(g)(1) requires knowing possession of a firearm; mere proximity to a gun is insufficient, and a separate mere-presence instruction is unnecessary when the instructions adequately convey that requirement.

United States v. Kenny Smart · filed 2023-02-21(g)(1)

Here, the instructions required the government to prove that “the defendant knowingly possessed a firearm,” that possession could be either actual or constructive, and defined constructive possession as having “both the power and the intention at a given time to exercise dominion or control over a thing.” The instructions thus required the jury to find that Smart knew he was in possession of a firearm, not that he was merely in the presence of it. As the instructions as a whole required the government to prove more than mere proximity to the gun, the district court did not abuse its discretion in refusing to give the requested instruction.
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A felon’s knowledge of a firearm in a car, its position, and his proximity to it can support an inference that he knowingly possessed it.

United States v. Ladeaux · filed 2023-03-03(g)(1)

Ladeaux’s knowledge that the car held a 12-guage shotgun, the gun’s position, and his proximity to it support an inference that he knowingly possessed the gun. The jury had sufficient evidence to convict.
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Section 922(g)(1) requires the government to prove that the defendant knowingly possessed a firearm.

United States v. Harrison · filed 2023-06-14(g)(1)

The government had the burden of proving Harrison knowingly possessed the weapon. It carried that burden.
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Section 922(g)(1)’s knowing-possession element can be proved by evidence connecting a felon to a firearm used in shootings.

United States v. Rodgers · filed 2023-11-02(g)(1)

Rodgers argues that the evidence at trial was insufficient for a reasonable jury to conclude beyond a reasonable doubt that he knowingly possessed a Beretta pistol. See United States v. Coleman, 961 F.3d 1024, 1027 (8th Cir. 2020) (noting “knowing possession of a firearm” as an element of 18 U.S.C. § 922(g)(1)). ... This evidence sufficed to prove Rodgers’s knowing possession of the Beretta, and the district court did not err in denying Rodgers’s motion for judgment of acquittal.
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Section 922(g)(1) permits knowing possession of a firearm to be proved through evidence of actual or constructive possession.

United States v. Byron · filed 2023-12-13(g)(1)

To obtain a conviction under 18 U.S.C. § 922(g), the government must prove that: (1) the defendant knew that he possessed (2) a firearm (3) that had travelled in interstate commerce (4) with knowledge of his status as one prohibited from possessing a firearm. ... The government’s evidence was more than sufficient for a jury to find beyond a reasonable doubt that Byron knowingly possessed, either actually or constructively, the firearm found under his seat.
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Section 922(g)(1)’s knowing-possession element can be proved by evidence that the defendant knew of and had dominion and control over the firearm.

United States v. Henry Watkins, Jr. · filed 2024-01-30(g)(1)

Viewing this evidence together and in the light most favorable to the jury’s verdict, there was sufficient evidence for a jury to infer that Watkins knew of and had dominion and control over the gun. Thus, a reasonable jury could conclude beyond a reasonable doubt that Watkins knowingly possessed the gun.
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Section 922(g)(1)’s knowing possession element can be proved by circumstantial evidence that the defendant threw an object and a gun was found where it landed.

United States v. Dixon · filed 2024-02-09(g)(1)

This evidence—which, contrary to Dixon’s assertion, goes beyond Dixon’s mere proximity to the firearm—is enough to support a rational trier of fact in finding Dixon knowingly possessed the gun.
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Section 922(g)(1) requires knowing possession of a firearm, which a jury may find from testimony and surrounding circumstances despite a defendant’s contrary account.

United States v. Ryan Fleming, Jr. · filed 2024-05-31(g)(1)

Mr. Fleming’s arguments for a new trial relate to the “knowing possession” element of his Section 922 offense and depend on events that occurred as he exited his vehicle after the crash. ... Further, in light of the dangerous high-speed chase, the jury was not required to accept Mr. Fleming’s assertions that he had not knowingly possessed the rifle while still in the vehicle.
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Section 922(g)(1)'s knowing possession element may be proved by evidence that the defendant identified where the gun was and had previously appeared with the same distinctive gun.

United States v. Billings · filed 2024-08-02(g)(1)

Viewed in the light most favorable to the Government, the evidence was sufficient to establish that Billings knowingly possessed the handgun. Thus, the district court did not err in denying the Rule 29 motion for judgment of acquittal.
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Section 922(g)(1) requires knowing possession of a firearm; mere presence near one does not establish voluntary and intentional possession.

United States v. Washington · filed 2024-11-22(g)(1)

Having received these instructions, the jury could not have attributed possession to Washington based on his mere presence in the vehicle where a gun was found because mere presence would not establish voluntary and intentional possession.
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Knowing possession under § 922(g)(1) can be proved by evidence that the defendant exercised dominion and control over a firearm.

United States v. Ellis · filed 2025-02-07(g)(1)

To convict Ellis under 18 U.S.C. § 922(g)(1), the government was required to prove: (1) Ellis had a prior conviction for a crime punishable by imprisonment exceeding one year; (2) he knowingly possessed a firearm; and (3) the firearm had been in or affected interstate commerce. ... The evidence presented at trial demonstrates more than mere proximity and was sufficient to establish Ellis knowingly possessed a firearm.
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Section 922(g)(1) requires proof that the defendant knowingly possessed the firearm; evidence that the defendant identified the gun and appeared in earlier images with it can support that finding.

United States v. Billings · filed 2025-02-27(g)(1)

Here, because the parties stipulated to the other elements, the only element in question at trial was whether Billings knowingly possessed the firearm. ... Viewed in the light most favorable to the Government, the evidence was sufficient to establish that Billings knowingly possessed the handgun. Thus, the district court did not err in denying the Rule 29 motion for judgment of acquittal.
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Section 922(g)(1) prohibits a convicted felon from knowingly possessing a firearm; a jury may find possession from circumstantial evidence that the defendant controlled and discarded the gun.

United States v. Gilmore · filed 2025-03-21(g)(1)

A reasonable jury could also conclude that Gilmore knowingly exercised dominion and control over the marijuana, methamphetamine, and gun before throwing them from the Charger.
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Section 922(g)(1)'s knowing-possession element can be proved without DNA evidence.

United States v. Humphrey · filed 2025-04-09(g)(1)

But DNA evidence is not necessary to show knowing possession.
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Section 922(g)(1)'s possession element can be satisfied by actual or constructive possession shown through direct or circumstantial evidence.

United States v. Kunkel · filed 2025-06-05(g)(1)

The government presented sufficient evidence for a rational jury to find that Kunkel possessed a firearm. Click testified that Kunkel threatened her with a gun, and she identified the gun at trial. And Stidham testified that, when he stopped Kunkel, a gun was visible from where Kunkel was sitting and no one else was in the vehicle. A rational jury could thus find that Kunkel had actual possession of the gun when he threatened Click, and at least constructive possession of the gun found in his truck.
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Section 922(g)(1)’s knowing possession element can be proved by circumstantial evidence, including firearms found along the defendant’s flight path.

United States v. Moses · filed 2025-07-30(g)(1)

Thus, despite Moses’s contrary arguments, there was sufficient circumstantial evidence from which a reasonable jury could have found beyond a reasonable doubt Moses knowingly possessed the firearms found in the bush along his flight path.
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Section 922(g) requires proof of knowing firearm possession, which a jury may find from circumstantial evidence.

United States v. Vanvacter · filed 2026-03-06(g)

The evidence, when viewed in the light most favorable to the verdict, was sufficient to permit a reasonable jury to find beyond a reasonable doubt that Vanvacter knowingly possessed the gun recovered by law enforcement following the traffic stop.
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Section 922(g)(1)’s knowing-possession element can be proved through actual or constructive possession of a firearm.

United States v. Mackie · filed 2026-03-11(g)(1)

The government may prove that a defendant knowingly possessed a firearm by showing that the defendant had either actual or constructive possession of a gun. ... And, based on the evidence in this case, we conclude that a reasonable jury could find—as this jury did—that Mackie knowingly possessed a gun between April 12 and ... April 20, 2023.
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Section 922(g)(1)'s knowing possession element may be proved by a firearm in plain view and other evidence supporting the defendant's knowledge.

United States v. Wilburn · filed 2026-04-03(g)(1)

We conclude that the evidence was sufficient to support the jury’s verdict. Wilburn relies on Swift’s exculpatory testimony at trial that she secreted the firearm and ammunition in the car without Wilburn’s knowledge. But the sheriff’s deputy testified that the firearm was found in plain view on the driver’s side of the vehicle. The jury was entitled to credit the deputy’s testimony and to infer that Wilburn knew about the gun. Wilburn’s previous unlawful possession of a firearm and the timing of Swift’s purchase further support the jury’s verdict.
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An eyewitness identification corroborated by the defendant’s presence and a nearby firearm can sufficiently prove knowing possession under § 922(g)(1).

United States v. Hernandez · filed 2026-05-08(g)(1)

On this record, a rational jury could find beyond a reasonable doubt that Hernandez knowingly possessed a firearm.
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Section 922(g)(1) requires proof that the defendant knowingly possessed a firearm.

United States v. Thomas · filed 2026-05-29(g)(1)

To prove a violation of Section 922(g)(1), the government must prove, among other things, that the defendant knowingly possessed a firearm.
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Section 922(g)(1) requires proof of knowing firearm possession; a stipulation to felon status does not establish that element.

United States v. Whitfield · filed 2025-06-24(g)(1)

Although Whitfield stipulated to being a convicted felon, he did not admit that he had the required intent of knowingly possessing the firearm. That means ... the government had the burden of proving “that [Whitfield] was in knowing possession of a firearm.” See Deleveaux, 205 F.3d at 1297.
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Sufficiency of evidence

Section 922(g)(1) prohibits a convicted felon from possessing ammunition, and a conviction can be supported by the defendant’s admission and ammunition found in his home.

United States v. Salter · filed 2025-03-18(g)(1)

As to Count Five, Salter admitted to possessing ammunition in his dresser, law enforcement found the ammunition in Salter’s home next to his driver’s license during the search, and Salter knew that, as a convicted felon, he was prohibited from possessing am- munition.
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Substantial evidence that a convicted felon possessed a firearm and ammunition supports convictions under § 922(g)(1).

United States v. Rice · filed 2015-09-11(g)(1)

On appeal, Rice asserts that the Government’s evidence was insufficient to establish that: (1) he possessed the firearm and ammunition for which he was convicted; and (2) the marijuana he possessed was for anything other than personal use. ... We have reviewed the record and have considered Rice’s arguments and conclude that, viewing the evidence in the light most favorable to the Government, there is substantial evidence to support the jury’s convictions on all counts.
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Section 922(g)(1) does not require direct evidence to support a conviction.

United States v. Clements · filed 2014-10-22(g)(1)

The government at all events does not need direct evidence to obtain a conviction under § 922(g)(1).
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Section 922(g)(1) prohibits a felon from possessing a firearm; eyewitness testimony that the defendant held and fired the gun can support a conviction.

United States v. Phillup Hicks · filed 2012-08-20(g)(1)

Viewing the evidence in the light most favorable to the Government, the evidence was sufficient for a rational trier of fact to find beyond a reasonable doubt that Hicks was guilty of being a felon in possession of a firearm.
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Section 922(g)(1)’s knowing possession element can be supported by eyewitness testimony that the defendant handled a gun and placed it in a car trunk.

United States v. Baker · filed 2012-06-28(g)(1)

Because Guereca saw Defendant place the gun in the trunk and remove it from the trunk, the jury could conclude Defendant had access to the trunk of the automobile where law enforcement found the gun. The jury did not have to pile inference upon inference to conclude Defendant knowingly possessed that gun.
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Section 922(g) supports a felon-in-possession conviction when the evidence permits a rational jury to find that the defendant possessed the firearm.

United States v. Williamson · filed 2012-05-30(g)

Because a rational trier of fact could have come to the conclusion that Williamson possessed the pistol that Detective Handley found in the closet, we conclude that the evidence was sufficient to support his conviction.
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Section 922(g)(1)'s possession element can be established by eyewitness testimony that the defendant held the firearm.

United States v. Wallace · filed 2012-05-22(g)(1)

Each officer testified that he saw Wallace in possession of the gun. In light of this eyewitness testimony, we hold that evidence of possession was established and that the district court correctly denied the Rule 29 motion.
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Section 922(g)(1) prohibits a felon from possessing a firearm; a stipulation to felony status and evidence of knowing possession supported this conviction.

United States v. Davis · filed 2010-06-15(g)(1)

The district court also did not err in denying the Rule 29 motion as to Count Two -- being a felon in possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(1) and 924. Davis stipulated to being a felon, and the prosecution presented evidence that Davis knowingly possessed two firearms.
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Section 922(g)(1)’s possession element is satisfied by proof that the defendant merely held the firearm.

United States v. Allen · filed 2009-12-22(g)(1)

Proof that Allen merely held the weapon is enough to establish possession.
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Section 922(g)(1)’s possession element can be proved by officers’ observations and the defendant’s admission, corroborated by recovery of the firearm.

United States v. Kelvin Miller · filed 2009-12-07(g)(1)

After viewing the evidence in the light most favorable to the verdict, see United States v. Urick, 431 F.3d 300, 303 (8th Cir. 2005), we conclude the evidence is sufficient to show Miller possessed a firearm.
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Section 922(g)(1) requires proof of possession of only one firearm to support a single felon-in-possession conviction.

United States v. Johnson · filed 2009-11-13(g)(1)

The defendant was charged with a single count of felon in possession; to convict, the government was required only to prove possession of one of the two firearms.
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Evidence that Denson knowingly possessed the firearm was sufficient to sustain his § 922(g)(1) conviction.

United States v. Denson · filed 2009-10-29(g)(1)

In conclusion, we find that the evidence was sufficient for a rational jury to find beyond a reasonable doubt that Denson knowingly possessed a firearm in violation of 18 U.S.C. § 922(g)(1).
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Section 922(g)(1)’s possession element can be supported by eyewitness testimony that the defendant held a gun and threw it away.

United States v. Thomas · filed 2009-10-07(g)(1)

At trial the parties stipulated that Thomas had a prior felony conviction and that the gun had traveled in interstate commerce, leaving the government to prove only that Thomas had possession of the gun. ... Counsel is correct, however, to reject each possibility as frivolous. Three eyewitnesses testified that they saw Thomas with the gun in his hand and saw him throw it over the fence, where it was immediately recovered.
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Section 922(g)(1) prohibits firearm possession by a person previously convicted of a crime punishable by more than one year; substantial evidence of possession can sustain a conviction.

United States v. Reid · filed 2009-10-09(g)(1)

Reid argues that there was insufficient evidence to demonstrate that he possessed the firearm. ... We have thoroughly reviewed the record and conclude that there is substantial evidence to support the jury’s verdict.
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Section 922(g)(1) requires proof that a convicted felon possessed a firearm; finding a gun in a jacket alone does not establish a violation.

United States v. Adams · filed 2009-10-14(g)(1)

Moreover, the fact that the gun was found in a jacket, without more, does not establish a violation of 18 U.S.C. § 922(g)(1).
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Section 922(g)(1)’s possession element can be supported by testimony that officers saw the defendant toss a gun away.

United States v. Williams · filed 2009-10-06(g)(1)

At trial the key issue was whether Williams possessed the gun (he conceded that he had a previous felony conviction and that the gun recovered by police had traveled in interstate commerce), but the jury heard testimony from two bystanders who saw Williams flee and from the police officers who saw Williams toss the gun away. Thus, we agree with counsel that any challenge based on the sufficiency of the evidence would be frivolous.
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Section 922(g)(1)'s possession element can be proved by evidence that the defendant tossed an object into an area where an officer then found a handgun.

United States v. Davis · filed 2009-10-01(g)(1)

Resolution of the credibility of both Davis and officer Book was squarely within the province of the district court, and the evidence adduced at trial was sufficient to show Davis possessed the handgun.
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Section 922(g)(1) and (j) possession convictions may stand when eyewitness testimony supports possession, even if the jury acquits the defendant of transporting the stolen firearm.

US v. Harris · filed 2009-09-23

In contrast, Matos did claim to have seen Harris in possession of the stolen items, and the jury found Harris guilty of both possession counts. There is no inconsistency between these verdicts.
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Section 922(g)(1) allows knowing possession of a firearm to be proved through evidence of actual or constructive possession, including circumstantial evidence.

United States v. Davis · filed 2009-08-20(g)(1)

In this case, the Government produced ample evidence for the jury to find that Defendant knowingly possessed a firearm.
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Section 922(g)(1)’s possession element may be proved by circumstantial evidence supporting an inference that the defendant possessed a firearm.

United States v. Reed · filed 2009-08-13(g)(1)

The Government presented evidence providing ample support for an inference that Reed was in possession of a firearm.
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A § 922(g)(1) conviction is supported by a stipulated prior felony and evidence that the defendant knew a loaded firearm was beneath the mattress in his room.

United States v. Barros · filed 2009-08-12(g)(1)

As to his being a felon in possession of a firearm and ammunition in violation of 18 U.S.C. §§ 922(g)(1) and 924(e) there can be no ... doubt. The parties stipulated to Barros’ prior felony conviction (R. Vol. 3 at 270) and he directed the officers to a loaded firearm beneath the mattress in his room.
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The alienage element of § 922(g)(5)(A) can be proved beyond a reasonable doubt through the defendant’s admissions and an immigration agent’s testimony.

United States v. Spencer · filed 2009-08-07(g)(5)(A)

The district court properly denied Rollier’s motion for a judgment of acquittal because the government proved her alienage beyond a reasonable doubt via her admissions and the immigration agent’s testimony.
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A convicted felon’s presence in a room with guns can support an inference of possession under § 922(g)(1).

United States v. Miller · filed 2008-10-27(g)(1)

Fines is guilty if he possessed guns any time during five years (the period of limitations) before the indictment. The pictures are relevant because they show that guns and Fines were in the room together, which supports an inference that he possessed them.
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Section 922(g)(1) requires proof that the defendant possessed a firearm; evidence permitting a jury to find possession supports a conviction.

United States v. Arnold · filed 2007-05-18(g)(1)

Arnold challenges the sufficiency of the evidence with regard to just one element of the crime: Did he possess a firearm? The jury heard several pieces of evidence that, when “view[ed] . . . in the light most favorable to the government,” would allow it to conclude just that.
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A conviction under § 922(g) cannot stand when the evidence is insufficient to sustain it.

United States v. Orisnord · filed 2007-04-11(g)

Based on the record and the Government’s concession, however, we conclude that the evidence was ... insufficient to sustain Witherspoon’s firearms convictions (Counts 4 and 5).
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A conviction under § 922(g)(1) may rest on evidence sufficient for a jury to find beyond a reasonable doubt that a convicted felon possessed a firearm.

United States v. Kurtis Tyrone Wright · filed 2007-04-12(g)(1)

We find that there was sufficient evidence for a jury to find that Wright was guilty beyond a reasonable doubt of possession of a firearm by a convicted felon under § 922(g)(1).
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Law changed since Rehaif v. United States, 588 U.S. 225 (June 21, 2019), also requires proof that a § 922(g) defendant knew of the status barring possession; knowledge of the interstate nexus remains unnecessary.

Section 922(g)(1) requires proof of a prior felony, knowing possession of a firearm, and a connection to interstate commerce.

United States v. Castro · filed 2007-05-30(g)(1)

On the firearm charge, likewise, M s. Lujan testified that on one occasion M r. Castro pointed a gun at her, pointed it at her car, and then started shooting at the car; this is sufficient for a jury to infer M r. Castro’s knowing possession of a firearm and thus a violation of the statutory prohibition against felons possessing firearms, particularly given M r. Castro’s stipulation to a prior felony conviction and the government’s evidence that the firearm had been made in M assachusetts and found in Oklahoma, thereby affording an interstate nexus.
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A § 922(g)(1) conviction is supported when the evidence, viewed in favor of the verdict, permits a rational jury to find guilt beyond a reasonable doubt.

United States v. Larkin · filed 2007-06-15(g)(1)

being a felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1). ... Viewing the evidence in the light most favorable to the verdict, we have determined that a rational trier of fact could have found that the evidence established Larkin’s guilt beyond a reasonable doubt as to both offenses.
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Witness testimony and recovery of a handgun can provide sufficient evidence of possession for convictions under § 922(g)(1) and § 922(k) despite challenges to witness credibility.

United States v. Hrobowski, Patrick · filed 2007-06-26(g)(1), (k)

Patrick Hrobowski was indicted in April 2005 for being a felon in possession of a handgun, see 18 U.S.C. § 922(g)(1), and knowingly possessing a handgun with an obliterated serial number, see 18 U.S.C. § 922(k). ... Hrobowski appeals, arguing that the evidence at trial was insufficient to support a conviction on either count. We affirm. ... None of the factual questions identified by Hrobowski undermine the sufficiency of the evidence against him.
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A sworn admission of firearm possession, corroborated by officers’ testimony, can provide sufficient evidence for a § 922(g)(1) conviction.

United States v. Dabney · filed 2007-08-02(g)(1)

On this record, a challenge to the sufficiency of the evidence is frivolous. Dabney’s admission under oath to possessing the gun was corroborated by the testimony of the officers who chased and apprehended him. Dab-ney identifies only minor, immaterial inconsistencies in the officers’ testimony. The evidence supporting this conviction is overwhelming.
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Evidence sufficient to establish the elements of unlawful firearm possession beyond a reasonable doubt supports a conviction under § 922(g)(1).

United States v. Smith · filed 2007-08-02(g)(1)

It is obvious that the evidence here is more than sufficient to establish each of the elements of 18 U.S.C. § 2119 (carjacking) beyond a reasonable doubt, and Smith’s arguments to the contrary to not merit discussion.3 The same is true of his Smith’s challenge to his conviction for using and carrying a firearm during a crime of violence in violation of 18 U.S.C. § 924,4 and unlawful possession of a firearm in violation of 18 ... U.S.C. § 922(g)(1).
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A conviction under § 922(g)(1) for possession of a firearm by a convicted felon stands when substantial evidence supports the jury’s verdict.

United States v. Fair · filed 2007-08-29(g)(1)

We have reviewed the record and find sufficient evidence to support the jury’s § 922(g)(1) and § 924(c)(1) convictions.
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Section 922(g)(1)’s possession element is satisfied when substantial evidence shows that a felon possessed at least one firearm charged in the indictment.

United States v. Saunders · filed 2007-09-11(g)(1)

Saunders claims that the evidence was insufficient to convict him under 18 U.S.C. § 922(g)(1) as a felon in possession of a firearm. ... This evidence allowed the jury to find that Saunders possessed one of the three guns listed in the indictment.
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A felon-in-possession conviction under § 922(g)(1) can stand when the evidence supports the jury’s verdict beyond a reasonable doubt.

United States v. Winston · filed 2007-09-13(g)(1)

Defendant Virgil J. W inston was found guilty after a jury trial of one count of being a Felon in Possession of a Firearm, in violation of 18 U.S.C. §§ 922(g)(1) and 924(e). ... Viewing the evidence in the light most favorable to the government, the verdict was amply supported by the evidence.
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Section 922(g)(1)’s possession element can be proved with a defendant’s confession when independent evidence corroborates it.

United States v. Davis · filed 2007-09-18(g)(1)

Here, the evidence shows that during the execution of the search warrant the officers found Davis in a rear bedroom, and the shotgun was in the closet. Also, there was evidence that Davis “use[d] the house as [his] own.” Such evidence fortifies Davis’s confession. We conclude that Davis has not shown that the record is devoid of evidence pointing to guilt or contains evidence on a key element of the offense that is so tenuous that a conviction would be shocking.
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Section 922(g)(1) possession and interstate commerce elements may be proved through witness testimony.

United States v. Walter Hoskins, III · filed 2007-11-30(g)(1)

A jury found Walter Hoskins guilty of being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(e)(1). ... we conclude there was sufficient evidence to support the conviction. Hoskins stipulated that he was a convicted felon; probation officers testified that during a visit to his apartment they saw the handle of a gun protruding from bedding; ... and a Bureau of Alcohol, Tobacco, and Firearms (ATF) agent testified that a handgun found in Iowa would have traveled in interstate commerce as handguns were not manufactured in Iowa.
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Section 922(g)(1)'s possession element may be supported by an officer's eyewitness testimony that the defendant held the firearm.

United States v. Molina · filed 2007-11-28(g)(1)

Sergeant O’Keefe testified that he was “100 percent” sure that he had seen Molina holding the gun. ... Hence, the evidence that Molina was guilty of the offense was sufficient for a reasonable jury to convict him.
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Section 922(g)(1)’s possession element can be established by evidence that the defendant placed an object where a firearm was then found.

United States v. Blackmon · filed 2007-12-11(g)(1)

We find that, viewing the evidence in the light most favorable to the Government and resolving all contradictions in the evidence in the Government’s favor, United States v. Lomax, 293 F.3d 701, 705 (4th Cir. 2002); Tresvant, 677 F.2d at 1021, there was sufficient evidence from which the jury could conclude that Blackmon was in possession of the firearm.
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Firearm possession under § 922(g)(1)-(3) may be proved by circumstantial evidence.

United States v. Tab · filed 2007-12-06(g)(1)-(3)

Tab’s challenge to the sufficiency of the evidence plainly lacks merit, as there was significant circumstantial evidence offered against him to support the jury’s finding that he possessed a gun on January 26, 2004.
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Section 922(g)(1)’s possession element was supported by evidence that the defendant identified a gun in his home and admitted it was his.

United States v. Simmons · filed 2008-03-18(g)(1)

Fourth, Simmons asserts the evidence was insufficient to convict him of the firearm charges. Simmons told police officers there was a gun in the bedroom, and after the officers found it in a heating duct, he admitted it was his. He now argues the gun could have been in the bedroom duct for years, but provides no support for his argument. Viewing the evidence in the light most favorable to the Government, it is sufficient to prove Simmons possessed the gun.
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A felon-in-possession conviction under § 922(g)(1) can stand even when officers find no gun on the defendant’s person, if the trial evidence is sufficient.

United States v. London · filed 2008-04-10(g)(1)

With these standards in mind, we have carefully considered London’s claims that the evidence was insufficient to convict him because officers did not find guns or drugs on his person during the search on May 5, 2005, and because Agent Tadeo’s testimony revealed that Edward Woods, a co-conspirator, was the drug supplier. Our review of the trial testimony convinces us that the evidence was sufficient to convict London on each count.
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Section 922(g)(1)’s possession element can be supported by evidence that the defendant acquired the charged firearm and was later seen carrying it.

United States v. Mora · filed 2008-04-25(g)(1)

We conclude that jurors could reasonably convict Mora of the charged offense — possession of the Glock 17 pistol with the serial number AHM397US — on this evidence.
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Evidence linking a defendant to guns found in a bedroom can establish possession under § 922(g).

United States v. Cole · filed 2008-05-15(g)(1), (g)(3)

Although Mr. Cole maintains that he had no connection to the first three guns because he was not living at the house when they were found, the contents of the bedroom provided a sufficient basis for a reasonable jury to connect Mr. Cole with the guns and find that he possessed them.
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Section 922(g)(1)’s possession element can be proved by testimony and circumstantial evidence sufficient for a rational jury to find possession beyond a reasonable doubt.

United States v. Drake · filed 2008-05-29(g)(1)

Testimony regarding the hat, in combination with Ellington’s testimony that the pistol grip of the weapon found by the fence was identical to the one that he viewed protruding from Drake’s coat, was sufficient for a rational trier of fact to establish, beyond a reasonable doubt, that Drake unlawfully possessed the weapon.
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Section 922(j) supports a conviction when the evidence is sufficient for a jury to find that the defendant knowingly possessed a stolen firearm.

United States v. Wirsch · filed 2008-06-30(j)

We have reviewed the trial testimony and find that the evidence presented by the government was sufficient to support the jury’s finding that Wirsch knowingly possessed the stolen firearm at issue.
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An admission of firearm possession can provide sufficient evidence for a § 922(g)(1) conviction.

United States v. Smith · filed 2008-07-01(g)(1)

Moreover, Spencer’s testimony that Smith admitted being in possession of the weapon leaves no doubt that the jury’s guilty verdict for being a felon in possession of a firearm was supported by sufficient evidence.
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Firearm possession under § 922(g) may be proved by circumstantial evidence and reasonable inferences.

United States v. Kimbrel · filed 2008-07-03(g)

In the second place, the government may indeed prove possession of a firearm by circumstantial evidence, which is why we will not overturn a felon-in-possession-of-a-firearm conviction “merely because [the jury] had to draw reasonable inferences to find [the defendant] guilty.”
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Section 922(g)(1)’s firearm element can be supported by evidence about a shotgun even when the prosecutor does not use the statute’s precise wording in questioning a witness.

United States v. Taylor · filed 2008-07-08(g)(1)

Taylor contends the evidence was insufficient for a reasonable juror to conclude the shotgun found in his bedroom was a firearm because the Government’s attorney did not use the precise statutory language when asking the ATF agent to identify the shotgun as a firearm. Nevertheless, the evidence was sufficient for the jury to conclude that the shotgun was a firearm within the meaning of the statute.
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A conviction under § 922(g)(1) can stand when the evidence sufficiently establishes that a felon possessed a firearm.

United States v. Harrison · filed 2008-07-18(g)(1)

Our review of the trial testimony convinces us that the evidence was sufficient to convict Harrison of being a felon in possession of a firearm.
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Section 922(g)(1)’s possession element may be proved by circumstantial evidence sufficient to support a guilty verdict beyond a reasonable doubt.

United States v. Nelson · filed 2008-07-22(g)(1)

The only element of 18 U.S.C. § 922(g)(1) that Nelson disputes is possession. ... We find that the government presented sufficient circumstantial evidence that, when viewed in the light most favorable to the government, sustains the jury’s verdict of guilty beyond a reasonable doubt.
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A defendant’s own statements can provide sufficient evidence that he knowingly possessed ammunition affecting interstate commerce under § 922(g)(1).

United States v. Griffin · filed 2008-08-19(g)(1)

The officers’ testimony regarding Griffin’s own statements at arrest provided ample evidence from which the jury could reasonably find that Griffin knowingly possessed ammunition that affected interstate commerce.
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Section 922(g)(1) permits proof of firearm possession through circumstantial evidence sufficient to support a finding of guilt beyond a reasonable doubt.

United States v. Flores · filed 2008-08-07(g)(1)

While it is true possession may be proved by circumstantial evidence, that evidence must still be sufficient to support the verdict. ... Here, the circumstantial evidence against Flores, although not eliminating every hypothesis of innocence, is quite sufficient to allow the jury to make reasonable choices that could support a finding of guilt beyond a reasonable doubt.
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Section 922(g)(1) prohibits a convicted felon from possessing a firearm or ammunition, and possession can be proved through an admission and surrounding evidence.

United States v. Allen · filed 2008-08-27(g)(1)

Even if that evidence were stricken, the record still supports conviction. The Officers observed a loaded handgun under the seat occupied by Allen. Allen directly admitted possessing the weapon when he told police that the gun was his wife’s and he was taking it to have it oiled and cleaned. A jury could have convicted on that evidence alone.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof beyond a reasonable doubt that the defendant was a convicted felon, knowingly possessed a firearm, and that the firearm was in or affecting interstate commerce.

United States v. Gordon · filed 2008-09-26(g)(1)

To establish a violation of 18 U.S.C. § 922(g)(1), the Government must prove beyond a reasonable doubt three elements: (1) that the defendant was a convicted felon, (2) that the defendant was in knowing possession of a firearm, and (3) that the firearm was in or affecting interstate commerce. ... The Government presented sufficient evidence on all three elements of the offense to support the jury’s guilty verdict.
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Section 922(g)(1)'s felon-in-possession offense is supported by evidence of a prior felony, an interstate nexus, and the defendant's possession of firearms.

United States v. Johnson · filed 2008-09-15(g)(1)

Finally, the evidence was sufficient to support the felon-in-possession conviction, as Johnson stipulated he was a convicted felon, the government presented evidence of an interstate nexus, the firearms were present in the house Johnson rented and the trailer he owned, and Hilde testified she recognized them as firearms that Johnson owned or showed her.
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Witness testimony that the defendant possessed a firearm can provide sufficient evidence for a conviction under § 922(g)(1) if the jury credits it.

United States v. Van · filed 2008-10-03(g)(1)

This testimony, if credited by the jury, was sufficient to convict Van of the felon in possession charge.
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Section 922(g)(1)’s possession element can be supported by witness testimony and the defendant’s admissions, even when the jury acquits on related weapons counts.

United States v. Smith · filed 2008-10-06(g)(1)

Conviction under 18 U.S.C. § 922(g)(1) requires that the defendant “had been previously convicted of a crime punishable by imprisonment of more than one year, that he knowingly possessed a firearm, and that the firearm had been in or affected interstate commerce.” ... Although the jury acquitted Smith of two related counts of possessing weapons, a jury may rationally convict on one count while acquitting on others. Sufficient evidence supports the conviction for possessing the Norico SKS rifle.
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A section 922(g)(1) conviction is supported by evidence that the defendant possessed a firearm, together with proof of a prior felony conviction and the firearm’s travel in interstate commerce.

United States v. Fisher · filed 2008-12-02(g)(1)

Fisher’s conviction is supported by the testimony of police officers that a gun was found protruding from beneath the driver’s seat of the car Fisher was driving when he was stopped for a traffic violation, the testimony of a passenger that the gun belonged to Fisher, and the parties’ stipulations about Fisher’s status as a convicted felon and the gun’s travel in interstate commerce.
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Evidence that a defendant was the only adult at a residence, was seen near a gun in plain view, and received a utility bill there can support the possession element of § 922(g)(1).

United States v. McCloud · filed 2008-12-18(g)(1)

The jury heard testimony that McCloud was the only adult present at the residence at the time of the raid and that, before fleeing upstairs as officers entered the residence, McCloud was initially seen in the foyer, where quantities of crack cocaine consistent with distribution and a loaded firearm were in plain view. Moreover, officers located a utilities bill for the premises addressed to McCloud on the same desk as the crack cocaine. When viewed in the light most favorable to the government, this evidence was sufficient to support the guilty verdicts on all counts.
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Section 922(g)(1) permits a felon-in-possession conviction when the evidence establishes possession, a qualifying prior conviction, and a connection to interstate commerce.

United States v. Goff · filed 2009-01-09(g)(1)

First, we conclude that the evidence at the March 2007 jury trial was sufficient. ... With regard to Count I, the testimony of two witnesses, whose credibility was for the jury, established that Goff actually possessed the firearm. ... The government also adduced evidence that the gun was loaded and that Goff was carrying a shotgun shell, the parties stipulated that Goff had been convicted of a crime punishable by imprisonment exceeding one year, and law enforcement officials testified that the shotgun and ammunition had traveled in interstate commerce.
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A defendant’s admission that he possessed firearms, supported by their proximity to his personal effects, can sustain a § 922(g) conviction.

United States v. Mitchell · filed 2009-01-13(g)

In the present case, we hold that there was ample evidence to support defendant’s conviction. Ballard testified that Mitchell admitted to possessing both firearms and all of the drugs found in the apartment.
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Under § 922(g), witness testimony that a defendant carried a firearm can support a finding of possession.

United States v. Humes · filed 2009-01-29(g)

Based on this testimony, and after viewing all of the evidence in the light most favorable to the government, a rational trier of fact could easily have found that Humes was in possession of the revolver on the evening of November 30, 2005.
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Section 922(g)(1) requires knowing possession of a firearm; evidence sufficient to establish possession supports a conviction.

United States v. Clark · filed 2009-02-09(g)(1)

Our review of the record leads us to conclude that Clark’s argument is without merit and that his reliance on United States v. Blue, 957 F.2d 106 (4th Cir. 1992), is misplaced. The evidence was sufficient.
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Section 922(g)(1)’s possession element may be proved by witness testimony and physical evidence, even when the defendant denies possessing the firearm.

United States v. Stackhouse · filed 2009-02-12(g)(1)

Thus, we conclude there was sufficient evidence for the jury’s guilty verdict determining that Stackhouse was a felon in possession of a firearm.
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Section 922(g)(1) bars convicted felons from possessing firearms or ammunition; proof of possession and undisputed felony status supports a conviction.

United States v. Rogers · filed 2009-03-03(g)(1)

Defendant’s status as a felon is undisputed, thereby making his possession of firearms in furtherance of this conspiracy a violation of 18 U.S.C. § 922(g)(1) as well.
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Section 922(g)(1) requires evidence connecting a defendant to the firearm; proximity to it alone does not prove possession.

United States v. Wakauwn · filed 2009-02-23(g)(1)

Some additional “connecting” evidence is necessary for the prosecution to meet its burden of proof.
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Section 922(g)(1) permits a felon-in-possession conviction when the evidence supports a finding beyond a reasonable doubt that the defendant possessed the firearm.

United States v. Williams · filed 2009-03-05(g)(1)

The evidence presented at trial was sufficient to permit a rational juror to conclude beyond a reasonable doubt that: Williams possessed the firearm ... Thus, we reject Williams’s challenge to the sufficiency of the evidence.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof that the defendant was a convicted felon, knowingly possessed a firearm, and that the firearm was in or affecting interstate commerce.

United States v. Lee · filed 2009-03-10(g)(1)

“To establish a violation of § 922(g)(1), the government must prove beyond a reasonable doubt three elements: (1) that the defendant was a convicted felon, (2) that the defendant was in knowing possession of a firearm, and (3) that the firearm was in or affecting interstate commerce.” ... Accordingly, Lee’s convictions do not constitute a manifest injustice, and we hold that the evidence was sufficient to support Lee’s convictions.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof that a convicted felon knowingly possessed a firearm with an interstate commerce nexus; eyewitness testimony can establish possession.

United States v. Smith · filed 2009-03-06(g)(1)

We disagree. The evidence of possession, while not overwhelming, was sufficient for a reasonable jury to conclude that Smith possessed the gun.
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Section 922(g)(1)’s possession element may be proved by evidence that a firearm was found where the defendant hid and that the property owner did not know of it.

United States v. LaDue · filed 2009-04-09(g)(1)

In this case, the government presented evidence that LaDue ran from an approaching patrol car and hid from police on a private driveway. Shortly thereafter, LaDue was arrested, and police found a firearm at the location where he had been hiding. The owner of the property where LaDue was found disclaimed any knowledge of the firearm, and testified that the gun was not present the previous evening. A reasonable jury could find on this record that LaDue possessed the firearm.
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Section 922(g)(1) permits a jury to find firearm possession from circumstantial evidence.

United States v. Ibanez · filed 2009-05-01(g)(1)

Here, the evidence was sufficient for the jury to convict Ibanez because the evidence showed that Ibanez was the man that Officer Wilson chased and arrested, and a firearm matching the pastor’s description was found directly in the flight path. Notwithstanding the discrepancy in the color of the tee-shirt, the circumstantial evidence was sufficient for a jury to conclude that Ibanez possessed a firearm.
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A felony stipulation and witness testimony that a firearm belonged to the defendant can suffice to support a conviction under § 922(g).

United States v. Wilson · filed 2009-05-14(g)

Regarding his conviction for being a felon in possession of a firearm, Wilson stipulated that he had been previously convicted of a felony. He does not challenge the seizure of the firearm from his residence. Witnesses testified that the firearm belonged to Wilson. This was sufficient to support a conviction under 18 U.S.C. § 922(g).
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Section 922(g)(1) prohibits a felon from possessing a firearm, and eyewitness testimony that the defendant held one can support a conviction.

United States v. Thomas · filed 2009-05-08(g)(1)

At trial, the apartment occupant testified that Thomas possessed a firearm when entering the apartment. ... This court concludes that the evidence supports the jury’s conviction, and the district court properly denied Thomas’s motion for judgment of acquittal.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof that a convicted felon knowingly possessed a firearm or ammunition with an interstate commerce connection; eyewitness testimony and the defendant’s description of the firearm can establish possession.

United States v. Welch · filed 2009-06-01(g)(1)

We conclude there was sufficient evidence to convict Welch of violating § 922(g)(1). The parties stipulated to each element except for possession and the evidence outlined above—including the fact that the officers testified they saw Welch carrying rifle and Welch’s own description of the rifle to the ATF agent—was sufficient to support a finding of possession.
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Section 922(g)(1)’s possession element can be proved through witness testimony and physical evidence identifying the firearm charged in the indictment.

United States v. Birdsong · filed 2009-06-03(g)(1)

However, the evidence overwhelmingly demonstrated that Birdsong not only possessed a firearm but that the firearm he possessed was a Hi-Point .380, the same firearm charged in the indictment.
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A defendant’s statement that a firearm is under his pillow, corroborated by officers who find it there, can support the possession element of § 922(g)(1).

United States v. Garcia · filed 2009-06-04(g)(1)

The jury, however, reasonably concluded that Garcia possessed the firearms. Agent Esquivel testified that Garcia responded to police that there was a weapon under his pillow, located where he had been sleeping.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof beyond a reasonable doubt that the defendant knowingly possessed a firearm, was a convicted felon, and that the firearm affected interstate commerce.

United States v. Lewis · filed 2009-06-15(g)(1)

We are satisfied after reviewing the record that the jury had sufficient evidence before it to convict Lewis of the charged offenses.
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Section 922(g)(1)’s possession element is satisfied when a felon knowingly handles a firearm.

United States v. Mose · filed 2009-06-10(g)(1)

Finally, there was sufficient evidence to support Mose’s conviction for being a felon in possession of a firearm. “[A] person is in ‘possession’ of something if the person knows of its presence and has physical control of it, or has the power and intention to control it.”
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Section 922(g)(1) supports a felon-in-possession conviction when the defendant admits agreeing to hold a gun and the prior conviction and gun’s interstate movement are established.

United States v. Tate · filed 2009-06-25(g)(1)

We conclude that the evidence was sufficient to sustain Tate’s conviction. ... Tate admitted to authorities that he had agreed to hold the gun for another individual. It was stipulated that Tate had been convicted of an offense punishable by a term of imprisonment of more than one year and that the gun in question had traveled in interstate commerce.
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Section 922(g)(1)'s possession element is satisfied when the evidence shows that a firearm was within the defendant's dominion and control.

United States v. Sims · filed 2009-09-18(g)(1)

The evidence was more than adequate to support the jury’s finding that the weapon was within Sims’s dominion and control.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof of a qualifying prior conviction, knowing possession of a firearm, and a connection between the firearm and interstate commerce.

United States v. Warbritton · filed 2010-01-12(g)(1)

Because the evidence at trial included testimony that Warbritton admitted the firearm found at the scene of his vehicle accident was his, and because he stipulated that the firearm had traveled in interstate commerce and that he had been convicted of a crime punishable by imprisonment exceeding one year, the court did not err in denying Warbritton’s motion for a judgment of acquittal.
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Section 922(g) requires proof that the defendant possessed a firearm; possession of one handgun can support a conviction even when possession of another is disputed.

United States v. Smith · filed 2010-01-27(g)

As an initial matter, Smith does not dispute that he possessed and dropped a handgun recovered immediately after his flight. In and of itself, that possession (and the evidence presented with respect to it) is sufficient to satisfy the elements of 18 U.S.C. §§ 922(g) and 924(e), and supports his conviction.
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Section 922(g)(1) supports a felon-in-possession conviction when evidence establishes a prior felony conviction and links the defendant to firearms transported in interstate commerce.

United States v. Shufelt · filed 2010-02-03(g)(1)

A search of the vehicle resulted in the recovery of five firearms, all of which had been transported in interstate commerce, from the back seat. This evidence, along with evidence of Shufelt’s admissions and fingerprint evidence, was ample to sustain Shufelt’s felon-in-possession conviction, particularly in light of defense counsel’s failure to move for a judgment of acquittal.
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Section 922(g)(1) prohibits a felon from possessing a firearm; evidence that the defendant handled the gun supported a finding of possession.

United States v. Deven Race · filed 2010-02-01(g)(1)

Race told the police that he handled the gun and that his DNA would be on it. This evidence is sufficient to sustain Race’s conviction for being a felon in possession of a firearm.
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Section 922(g)(1) prohibits a convicted felon from knowingly possessing ammunition in or affecting interstate commerce.

United States v. Carter · filed 2010-02-18(g)(1)

Based on the witness testimony and the physical evidence found in the Dodge, we conclude that the government presented sufficient evidence for a jury to convict Carter of knowingly possessing ammunition in or affecting interstate commerce.
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Section 922(g)(1) requires proof of a prior felony conviction, firearm possession, and the firearm’s travel in interstate commerce; officers’ testimony that they saw the defendant discard a gun can support the possession element.

United States v. Steplight · filed 2010-02-24(g)(1)

The parties stipulated at trial to two of the three elements of unlawful possession of a firearm by a convicted felon. Specifically, they stipulated that Steplight was convicted of a felony and that the firearm had traveled in interstate commerce. The final element of the crime was Steplight’s possession of the firearm. ... Given the police officer’s testimony, the jury clearly had a reasonable basis for finding that Steplight possessed the firearm, the only non-stipulated element of the charged crime.
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Section 922(g)(1)'s possession element is satisfied when a rational juror could find beyond a reasonable doubt that the defendant possessed either charged firearm.

United States v. Navarette · filed 2010-04-22(g)(1)

Viewing this evidence in the requisite light most favorable to the Government, a rational trier of fact could have found, beyond a reasonable doubt, that Navarette possessed either firearm.
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Circumstantial evidence linking a firearm to a defendant’s residence and belongings can support a finding of possession under § 922(g)(1).

United States v. Greer · filed 2010-06-11(g)(1)

We conclude that the evidence supports the verdict. Greer rented the residence where police found the revolver. The gun was found in a purse inside a coat in a locked bedroom closet. Also in the purse was a phone bill addressed to Greer and a money order payable to Greer. Police found correspondence addressed to Greer on a dresser in the bedroom. In another coat in the same closet, police found hydrocodone that Greer admitted belonged to him. A reasonable jury could find that Greer possessed the firearm.
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Section 922(g)(1) prohibits a person convicted of a felony from possessing a firearm; circumstantial evidence can prove possession.

United States v. Culbertson · filed 2010-08-11(g)(1)

This evidence is sufficient for a rational trier of fact to infer that the gun the officers recovered was indeed the object Culbertson tossed while being chased. Sufficient evidence therefore existed to find Culbertson guilty of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).
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Section 922(g)(1) permits a felon-in-possession-of-ammunition conviction when sufficient evidence shows possession, a qualifying felony conviction, and interstate travel of the ammunition.

United States v. Demario Griffin · filed 2010-09-29(g)(1)

But the detective’s testimony about Griffin’s initial admission, Griffin’s stipulation that he had been convicted of a crime punishable by a term of imprisonment exceeding one year, and undisputed evidence that the ammunition had traveled in interstate commerce were sufficient to support the verdict.
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Law changed since Same change as noted above.

Section 922(g)(1) requires proof of a qualifying prior conviction, knowing possession of a firearm, and a connection between the possession and interstate commerce.

United States v. Pindle · filed 2010-11-19(g)(1)

The evidence also was sufficient to convict Pindle of violating § 922(g). It was stipulated at trial that Pindle was a convicted felon and that the gun was not manufactured in Virginia. Further, Pindle admitted that he had possessed the gun.
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Notes 6001–6150 of 8,290, oldest cases first.

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