What is the standard of review for imputed possession of metal knuckles?

California, United States of America


The following excerpt is from People v. Triplett, B259575 (Cal. App. 2015):

"In assessing a claim of insufficiency of evidence, the reviewing court's task is to review the whole record in the light most favorable to the judgment to determine whether it discloses substantial evidencethat is, evidence that is reasonable, credible, and of solid valuesuch that a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt. [Citation.] The federal standard of review is to the same effect: Under principles of federal due process, review for sufficiency of evidence entails not the determination whether the reviewing court itself believes the evidence at trial establishes guilt beyond a reasonable doubt, but, instead, whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." (People v. Rodriguez (1999) 20 Cal.4th 1, 11.) "'"'"If the circumstances reasonably justify the trier of fact's findings, the opinion of the reviewing court that the circumstances might also reasonably be reconciled with a contrary finding does not warrant a reversal of the judgment."'"'" (Ibid.)

Defendant recognizes that possession of the metal knuckles may be actual or constructive. Constructive possession occurs when a defendant has control or the right to control the item in the actual possession of another. (People v. Morante (1999) 20 Cal.4th 403, 417.) Possession may be imputed if an item is "subject to the joint dominion and control of the accused and another." (People v. Francis (1969) 71 Cal.2d 66, 71.) Consistent with these principles, jurors were instructed that "[a]

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