What is the test for constructive possession in a drug case?

"Constructive possession may also be proven by the defendant's participation in a joint venture to possess a controlled substance." Disla, 805 F.2d at 1350 (citing United States v. Valentin, 569 F.2d 1069, 1071 (9th Cir.1978) ). "[C]oordinated activity among the defendants raises a reasonable inference of a joint venture." United States v. Smith, 962 F.2d 923, 930 (9th Cir.1992) (quoting United States v. Hernandez, 876 F.2d 774, 778 (9th Cir.1989) (alteration in original)). "In addition to association, the government must also establish that the defendant had a role in directing or planning the acquisition or transportation of the drugs." Id.

Lemus argues that without corroboration, his own inculpatory statements made during the offense cannot support a conviction. Lemus relies upon United States v. ValdezNovoa, 780 F.3d 906, 922 (9th Cir.2015). However, ValdezNovoa involved a defendant's confession, not contemporaneous statements. Id. And, ValdezNovoa framed the rule as directed to confessions: "the contemporary iteration of the common law corpus delicti rule" is that "[a]lthough the government may rely on a defendant's confession to meet its burden of proof ... in order to serve as the basis for conviction, the government must also adduce some independent corroborating evidence." Id.