The following excerpt is from U.S. v. Savinovich, 845 F.2d 834 (9th Cir. 1988):
Savinovich argues there is insufficient evidence to support her conviction. Specifically, she argues that (1) she did not know her bag contained cocaine; (2) her possessory interest in the cocaine was insufficient to support conviction; and (3) there was no basis for the inference that she intended to distribute the drug. Viewing the evidence in the light most favorable to the government, we review these allegations to determine whether a rational jury could find Savinovich guilty beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 324, 99 S.Ct. 2781, 2791, 61 L.Ed.2d 560 (1979).
1. Possession
A person may not be convicted of illegal possession of contraband unless she can exercise dominion and control over it. United States v. Disla, 805 F.2d 1340, 1350 (9th Cir.1986). Mere proximity to the drug, presence on the property where it is located, or association with the person who controls the drug is insufficient to support conviction for possession. See id. at 1351. But if there is a rational basis for attributing interest in the contraband to one party because of relationship with another, a trier of fact can infer sufficient knowledge to support a conviction for possession. United States v. Hood, 493 F.2d 677, 681 (9th Cir.) (defendant was married to driver of drug-laden car and had reason to know his destination and criminal intent), cert. denied, 419 U.S. 852, 95 S.Ct. 94, 42 L.Ed.2d 84 (1974). Furthermore, a defendant's exclusive dominion over property on which contraband is found is strong circumstantial evidence of possession. See United States v. Walitwarangkul, 808 F.2d 1352, 1354 (9th Cir.), cert. denied, --- U.S. ----, 107 S.Ct. 1909, 95 L.Ed.2d 515 (1987).
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