People v. Manini, 79 N.Y.2d 561 (1992)
Mere presence in a public place, even one where contraband is in plain view, is insufficient to establish dominion and control over the contraband necessary for constructive possession.
Summary
The New York Court of Appeals reversed in part the Appellate Division’s order, finding insufficient evidence to support the defendant’s conviction for criminal possession of a controlled substance. The defendant was arrested while exiting a back room of a grocery store where cocaine was in plain view. The Court held that the prosecution failed to prove the defendant owned, rented, controlled, or had a possessory interest in the store or back room, or that he was involved in any drug-related activities there. The mere presence in the room, even with visible contraband, was insufficient to establish constructive possession.
Facts
Police officers entered a grocery store and observed the defendant and three other individuals exiting a back room, walking quickly toward the front exit. In the back room, contraband (cocaine) was in plain view. There was no evidence presented that the defendant owned, rented, or had any control or possessory interest in the grocery store or the back room itself. Furthermore, there was no evidence linking the defendant to any drug-selling or related operations within the store.
Procedural History
The defendant was convicted on multiple counts, including criminal possession of a controlled substance. The Appellate Division affirmed the conviction. The New York Court of Appeals reviewed the Appellate Division’s order.
Issue(s)
Whether the evidence presented by the People was legally sufficient to establish that the defendant had constructive possession of the cocaine found in the back room of the grocery store.
Holding
No, because the People failed to establish that the defendant exercised dominion and control over the cocaine or the area where it was found. Mere presence in a room where contraband is visible is insufficient to prove constructive possession.
Court’s Reasoning
The Court of Appeals focused on the requirements for establishing constructive possession. Constructive possession requires demonstrating dominion and control over the contraband itself or the area where the contraband was located. The Court emphasized that the prosecution failed to provide any evidence linking the defendant to the grocery store or the back room. Specifically, there was no proof of ownership, rental agreement, or any other possessory interest held by the defendant. Furthermore, the prosecution did not present evidence that the defendant was involved in any drug-selling activities occurring at that location. The Court distinguished this case from People v. Tejeda, where a statutory presumption of possession applied because the drugs were found in an apartment where the defendant was present. The Court cited People v. Headley, stating that “Presence in a public place does not itself prove dominion and control over contraband discovered there.” The court found the evidence insufficient to establish the defendant’s constructive possession of the cocaine, requiring vacatur of the conviction on those counts.