What is the test for "mere possession" of a firearm?

"A defendant's 'mere possession' of a firearm or deadly weapon does not establish that the defendant was armed with the firearm or deadly weapon." (People v. Burnes (2015) 242 Cal.App.4th 1452, 1458.) The reason is that a defendant's possession may be constructive, with little actual accessibility: "'Obviously, a firearm that is available for use as a weapon creates the very real danger it will be used.' [Citation.] The same cannot necessarily be said about a firearm that is merely under the dominion and control of a person previously convicted of a felony. For instance, a firearm passed down through family members and currently kept in a safe deposit box by a convicted felon would be

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