United States v. Haile

The federal government (plaintiff) obtained the convictions of Randy Vana Haile and Mark Anthony Beckford (defendants) on several counts relating to drug and firearm offenses. Count 6 charged Beckford with possession of a firearm bearing an obliterated serial number, in violation of 18 U.S.C. § 922(k). On appeal, the Eleventh Circuit Court of Appeals affirmed each of Haile's and Beckford's other convictions before considering Beckford's appeal of his conviction on Count 6. As to that count, the trial evidence established that federal agents arrested Beckford when he drove his truck to a prearranged location to trade cash and guns for drugs. Beckford had set up the exchange with a "dealer" who turned out to be working undercover for the government. The agents found cash, a handgun, a machine gun, two rifles, and ammunition in Beckford's truck. Because these items were stashed in the back of the truck and therefore out of Beckford's reach, the government could not establish actual possession, but the evidence was sufficient to show that Beckford had constructive possession of the items. The serial number on one of the rifles had been obliterated. There was no direct evidence that Beckford had actual knowledge of the obliteration. However, the government asserted that the jury could infer Beckford's knowledge from the ample opportunity he had to discover the obliteration. The government offered no proof as to how long Beckford had the rifle in his constructive possession.