Woods V State 2d 22 (1973)

Id. There was no evidence presented by the prosecution that the defendants knew about the drugs or even knew that there was a cooler in the cargo area. Id. at 806. The prosecution cited no authority for the proposition that a jury could infer knowledge of the drugs because of employment status. Id. at 807. The court reasoned that the occupants’ stories were not inconsistent and that knowing the owner does not lead a reasonable person to infer that the defendants knew the drugs were in the cooler. Id. The government offered no evidence to suggest the defendants’ explanation for traveling was false. Id. at 805-06. There was no evidence, such as fingerprints, that would link the defendants to the drugs. Id. at 806. Lastly, the court

Reeves, 209 N.W.2d 18, 22 (Iowa 1973)); Woods v. State, 765 So. 2d 255, 257 (Fla. Dist. Ct. App. 2000) (citing S.B. v. State, 657 So. 2d 1252, 1253 (Fla. Dist. Ct. App. 1995); Murphy v. State, 511 So. 2d 397, 399 (Fla. Dist. Ct. App. 1987)). See also State v. Bristol, 98 S.W.3d 107, 111 (Mo. Ct. App. 2003) (citing State v. Bowyer, 693 S.W.2d 845, 847 (Mo. Ct. App. 1985)) (holding that “[i]f there was joint control over the place where the drugs were found, further evidence is necessary to connect [the defendant] with the drugs”); In Interest of E.H., 579 So. 2d 364, 365 (Fla. Dist. Ct. App. 1991) (holding that the evidence was insufficient to prove knowledge of a rock of cocaine hidden between driver's seat and transmission tunnel because the defendant was not sole occupant of the vehicle, even though he was in the driver's seat, admitted he was in the high crime area to buy marijuana, and admitted he knew that the passenger possessed marijuana on his person); People v. Roundtree, 482 N.E.2d 693, 698 (Ill. App. Ct. 1985) (holding that the state failed to produce sufficient evidence to prove knowledge of the contents of a suitcase containing cocaine, located on the rear seat of vehicle in which the defendant was one of three passengers in the vehicle); Johnson v. State, 625 S.W.2d 330, 330-331 (Tex. Crim. App. 1981) ((holding that the evidence was insufficient to support a conviction of possession of marijuana when

Id. Id. Rivas v. United States, 783 A.2d 125 (D.C. 2001). Id. at 145. When only one person is in possible constructive possession, it “then also becomes relevant to know the period of time during which the person has been in "exclusive" proximity, and evidence that others may have been responsible for the contraband's presence may render the situation just as ambiguous as when more than one person is present.” Id. at 145 n.22. See supra note 123 (discussing State v. Bristol, a case with a similar fact pattern). Rivas, 783 A.2d at 128-29. Id. at 128. Id. at 145. Utah v. Salas, 820 P.2d 1386, 1388 (Utah Ct. App. 1991). See also State v. Johnson, 81 S.W.3d 212, 216 (Mo. Ct. App. 2002) (holding that if the accused is the owner or renter of the vehicle, possession will not be inferred where others have had equal access to the vehicle, absent evidence of additional incriminating circumstances implicating defendant). Id. (quoting Utah v. Fox, 709 P.2d 316, 319 (Utah 1985)). See also UTAH CODE ANN. § 58-37-8(1)(a)(iii) (2016) (stating that “[e]xcept as authorized by this chapter, it is unlawful for any person to knowingly and intentionally possess a controlled or counterfeit substance with intent to