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United States v. Clark

United States Court of Appeals for the Second Circuit
740 F.3d 808 (2014)


Facts

The federal government (plaintiff) prosecuted Jeremiah K. Clark (defendant) for possession of a controlled substance. The trial evidence established that police arrested Clark in connection with a reported assault. A patdown turned up nothing suspicious. Officers securely handcuffed Clark, placed him in the back seat of a police car, and drove him to the police station, about one minute away. The link between Clark's two handcuffs was no more than one-and-a-half inches long. Prior to Clark's arrest, an officer checked the back seat to make sure it was clean. The officer checked the seat again after Clark exited the vehicle and found a bag of crack cocaine about five inches long and one inch wide wedged under the seat. Some of the cocaine powder had spilled out of the bag. Until then, no one had observed cocaine dust on the seat or on Clark's clothing. Officers searched Clark at the station and found no cocaine on his person. The jury convicted Clark, and on appeal to the Second Circuit Court of Appeals, he challenged the sufficiency of the evidence against him.

Rule of Law

Issue

Holding and Reasoning (Newman, J.)

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