Possession of meth; MCL 333.7403(2)(b)(i); Sufficiency of the evidence; Constructive possession; Dominion or control; Knowledge; People v McKinney; People v Wolfe; Circumstantial evidence; Reasonable inferences; People v Carines; People v Hardiman

The court held that sufficient evidence supported defendant’s meth-possession conviction because the totality of the circumstances established a sufficient nexus between him and the contraband. After a bench trial, defendant was convicted of possession of meth and acquitted of delivery or manufacture. Police found him hiding in a bedroom closet, discovered meth and drug-use items in the room, and found his wallet in a backpack outside the bedroom with empty syringes similar to syringes found in the room. On appeal, the court held that the evidence allowed a rational trier of fact to find “dominion or right of control over the drug with knowledge of its presence and character.” The court reasoned that defendant was one of only two people in the bedroom, the meth and related items were accessible there, his backpack connected him to similar syringes, and his hiding in the closet supported an inference that attempts were being made to conceal the drugs. It also relied on evidence that he had previously visited the home to use drugs and admitted he was a drug user who had used meth hours before his arrest. Affirmed.