State v. Jones

Court of Appeals of North Carolina·Decided September 17, 2025·No. 24-959·Unpublished

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-959

Filed 17 September 2025

Nash County, Nos. 23CRS000609-630, 23CRS000610-630, 23CRS209142-630

STATE OF NORTH CAROLINA

v.

TYQUAN JAMEEL JONES, Defendant.

Appeal by defendant from judgment entered 9 August 2023 by Judge Thomas

H. Lock in Nash County Superior Court. Heard in the Court of Appeals 6 August

2025.

Appeal by defendant from judgment entered 9 August 2023 by Judge Thomas

H. Lock in Nash County Superior Court. Heard in the Court of Appeals 6 August

Attorney General Jeff N. Jackson, by Assistant Attorney General Justin M. Bradley, for the State.

King & Moss, PLLC, by John W. Moss, for defendant-appellant.

PER CURIAM.

Defendant Tyquan Jameel Jones appeals from a trial court’s judgment finding STATE V. JONES

Opinion of the Court

him guilty of possession of a firearm by a felon and carrying a concealed weapon. On

appeal, Defendant argues the trial court erred by not granting Defendant’s motion to

dismiss because Defendant did not have constructive possession of the firearm where

he lacked the knowledge that the firearm was in the vehicle. After careful review, we

conclude the trial court did not err as the State presented sufficient evidence that

Defendant constructively possessed the firearm.

I. Factual and Procedural Background

On 12 January 2023, Officer Richard Lafayette of the Nash County Sheriff’s

Office was conducting his usual patrol duties when, upon passing at a convenience

store on N.C. Highway 581, he spotted a black Volvo with the back of the vehicle

covered in mud, making the license plate “illegible.” Officer Lafayette followed the

vehicle on N.C. Highway 581 and turned on his lights and sirens. The driver of the

vehicle waited two to three minutes before pulling over, during which time the driver

made a right turn and did not appear to notice Officer Lafayette. After the driver

pulled over and stopped, Officer Lafayette approached the vehicle, noticed a

marijuana odor coming from the open window of the vehicle, and observed that the

driver—later identified as Defendant Tyquan Jones—was bent over with his hands

located out of Officer Lafayette’s sight. Officer Lafayette also noticed a male in the

passenger’s seat, later identified as Jonathan Mbumba. Officer Lafayette asked

Defendant to place his hands on the steering wheel, and Defendant complied.

Officer Lafayette called for another officer to wait with Mbumba while Officer

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Lafayette asked Defendant to sit in the patrol car while Officer Lafayette wrote a

warning ticket for the obscured license plate. In the patrol car, Defendant admitted

he “smoked marijuana in the car earlier that day” and that there “might be marijuana

cigarettes . . . inside the vehicle[.]” Upon hearing these statements, Officer Lafayette

informed Defendant the vehicle would be searched. When Officer Lafayette asked

Defendant if there was anything in the vehicle that could harm Officer Lafayette,

Defendant answered that he was “unsure,” but his girlfriend usually kept a firearm

in the car. Officer Lafayette searched the vehicle and found a blue and black Glock

43x 9-millimeter handgun under the driver’s seat, approximately seven inches from

where the seat “actually curves.” The firearm was registered to Defendant’s

girlfriend, Latricia Marquesha. Additionally, although the license plate on the vehicle

Defendant was driving was registered under Marquesha’s name, the license plate

was not registered to the vehicle itself. Marquesha was not present at the time of the

traffic stop or arrest.

On that same day, Officer Lafayette arrested Defendant for possession of a

firearm by a felon. On 6 March 2023, Defendant was indicted for possession of a

firearm by a felon, carrying a concealed weapon, and attaining habitual felon status.

The matter came on for trial on 7 August 2023. At trial, Defendant moved to

dismiss the possession of a firearm by a felon charge and moved for a directed verdict

because he did not know the contents of the vehicle and therefore could not have

constructively possessed the firearm. The trial court denied both motions. On 9

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August 2023, the jury returned a guilty verdict, after which Defendant moved for a

judgment notwithstanding the verdict. The trial court dismissed Defendant’s motion.

In return for the trial court’s finding mitigating factors, Defendant pled guilty to the

habitual felon indictment and was sentenced to sixty-six to ninety-two months of

imprisonment. Defendant timely appealed.

II. Jurisdiction

This Court has jurisdiction to hear an appeal from a final judgment of a

superior court, pursuant to N.C.G.S. § 15A-1444(a) (2023).

III. Analysis

Defendant argues the trial court erred by not granting his motions to dismiss.

Specifically, Defendant argues he did not know the firearm was in the car and,

therefore, could not have had the intent and power to control it as required for

constructive possession.

“This Court reviews the trial court’s denial of a motion to dismiss de novo.”

State v. Marley, 227 N.C. App. 613, 614 (2013) (citations omitted). The trial court

properly denies a motion to dismiss if “there is substantial evidence . . . of each

essential element of an offense charged, or of a lesser offense included therein, and .

. . of [the] defendant[] being the perpetuator of such offense.” Id. at 614. “Substantial

evidence is such relevant evidence as a reasonable mind might accept as adequate to

support a conclusion.” Id. at 615. In considering the evidence, the trial court must

give the State “the benefit of every reasonable inference and resolv[e] any

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contradictions in its favor.” Id. at 615.

Pursuant to N.C.G.S. § 14-415.1(a), “[i]t shall be unlawful for any person who

has been convicted of a felony to purchase, own, possess, or have in his custody, care,

or control any firearm or any weapon[.]” N.C.G.S. § 14-415.1(a) (2023); see also State

v. Mitchell, 224 N.C. App. 171, 176 (2012) (“There are two elements to possession of

a firearm by a felon: (1) defendant was previously convicted of a felony; and (2)

thereafter possessed a firearm.” (citations and internal quotation marks omitted)).

Possession may be actual or constructive. See State v. Malachi, 371 N.C. 719,

730 (2018). “Actual possession requires that a party have physical or personal custody

of the item,” while constructive possession occurs when “the item is not in [the

defendant’s] physical custody, but he nonetheless has the power and intent to control

its disposition.” State v. Alston, 131 N.C. App. 514, 519 (1998) (citations omitted).

This Court has consistently held that “the driver of a borrowed car, like the owner

of the car, has the power to control the contents of it.” State v. Best, 214 N.C. App. 39,

47 (2011) (citations and internal quotation marks omitted). “Moreover, power to

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Related

State v. Alston
508 S.E.2d 315 (Court of Appeals of North Carolina, 1998)
State v. Best
713 S.E.2d 556 (Court of Appeals of North Carolina, 2011)
State v. Malachi
821 S.E.2d 407 (Supreme Court of North Carolina, 2018)
State v. Mitchell
735 S.E.2d 438 (Court of Appeals of North Carolina, 2012)
State v. Marley
742 S.E.2d 634 (Court of Appeals of North Carolina, 2013)