United States v. Whitehead

CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 25, 2025
Docket24-6062
StatusUnpublished

This text of United States v. Whitehead (United States v. Whitehead) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Whitehead, (10th Cir. 2025).

Opinion

Appellate Case: 24-6062 Document: 55-1 Date Filed: 03/25/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT March 25, 2025 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-6062 (D.C. No. 5:23-CR-00280-J-1) OTIS RAY WHITEHEAD, JR., (W.D. Okla.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT* _________________________________

Before MORITZ, EID, and FEDERICO, Circuit Judges. _________________________________

Otis Ray Whitehead, Jr., appeals his conviction and sentence on one count of

being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).

Exercising jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742, we affirm.1

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 1 Judge Federico joins this Order and Judgment except for Part II.B. Appellate Case: 24-6062 Document: 55-1 Date Filed: 03/25/2025 Page: 2

I. Background

Whitehead was the subject of an investigation by the Oklahoma City Police

Department (“OCPD”). In March 2023, OCPD officers executed a search warrant at

a two-bedroom residence located at 2237 Northwest 32nd Street in Oklahoma City.

There, officers found Whitehead, his brother Tylin Childers, three of Whitehead’s

teenage nephews, and Whitehead’s teenage sister. A search uncovered a handgun in

the pocket of a jacket hanging over a closet door in one of the bedrooms. They

arrested Whitehead and Childers, each of whom had prior felony convictions.

The Government charged Whitehead with one count of being a felon in

possession of a firearm in violation of 18 U.S.C. § 922(g)(1). The jury found

Whitehead guilty. The district court applied a sentencing enhancement for

obstruction of justice and sentenced Whitehead to 87 months of imprisonment.

Whitehead appeals.

II. Discussion

Whitehead raises three issues on appeal, challenging (1) the sufficiency of the

evidence, (2) the enhancement for obstruction, and (3) the constitutionality of

§ 922(g)(1). We address the issues in order.

A. Sufficiency of the evidence

1. Standard of review

“We review the sufficiency of the evidence to support a conviction de novo to

determine whether, viewing the evidence in the light most favorable to the

government, any rational trier of fact could have found the defendant guilty of the

2 Appellate Case: 24-6062 Document: 55-1 Date Filed: 03/25/2025 Page: 3

crime beyond a reasonable doubt.” United States v. Stepp, 89 F.4th 826, 831–32

(10th Cir. 2023) (internal quotation marks omitted). “In conducting this review, we

consider all of the evidence, direct and circumstantial, along with reasonable

inferences, but we do not weigh the evidence or consider the relative credibility of

witnesses.” Id. at 832 (internal quotation marks omitted). “Thus, our review is

limited and deferential; we may reverse only if no rational trier of fact could have

found the essential elements of the crime beyond a reasonable doubt.” Id. (internal

quotation marks omitted).

2. Constructive possession principles

To convict Whitehead “under § 922(g)(1), the Government had to prove,

among other things, that he knowingly possessed . . . a firearm.” Id. (internal

quotation marks omitted). Although “[p]ossession may be actual or constructive,”

id., there is no dispute that this case involves only constructive possession.

“Constructive possession exists when a person, not in actual possession, knowingly

has the power and intent at a given time to exercise dominion or control over an

object.” Id. (brackets and internal quotation marks omitted). “When a defendant has

exclusive control over the premises where an object is found, a jury may infer

constructive possession.” Id. (internal quotation marks omitted). “But when a

defendant jointly occupies the premises, the Government must show a nexus between

the defendant and the firearm . . . .” Id. (internal quotation marks omitted). “That is,

the Government must demonstrate the defendant knew of, had access to, and intended

to exercise dominion or control over the contraband.” Id. (brackets and internal

3 Appellate Case: 24-6062 Document: 55-1 Date Filed: 03/25/2025 Page: 4

quotation marks omitted). “This may be proved by circumstantial as well as direct

evidence.” Id. (internal quotation marks omitted). “Multiple individuals may have

constructive possession of the contraband; exclusive possession is not required.”

Id. at 833. “But the defendant’s joint occupancy alone cannot sustain an inference of

constructive possession.” Id. (internal quotation marks omitted).

3. Whitehead’s argument

Whitehead concedes that “the Government presented ample evidence that [he]

knew about the gun and had access to it,” but argues that “nothing presented to the

jury supports a finding he intended to exercise control over it.” Aplt. Opening Br.

at 25. He contends the evidence is insufficient to support the Government’s claim

that the bedroom where the gun was found was solely his because at the time of the

search, his sister was sleeping in there. He argues that at most, the evidence showed

he jointly occupied that bedroom.

We disagree. We first summarize the relevant evidence and then explain why

it was sufficient to support the conviction.

4. Trial evidence

Officer Harmon was the lead officer conducting the search. At trial, he

testified that when he entered the house, he saw Whitehead at the back of the living

room and “ordered [Whitehead] out,” but Whitehead “did not comply.” R. vol. III

at 29:7. Whitehead then “ducked around the corner to the west and then later came

back out into the living room.” Id. at 29:8–9. The area he “ducked into” contained

the southwest bedroom where the gun was found. See id. at 29:11–13; see also id.

4 Appellate Case: 24-6062 Document: 55-1 Date Filed: 03/25/2025 Page: 5

at 33:10 (describing the bedroom where the gun was found as the “southwest

bedroom”). Whitehead returned to the living room in “a matter of seconds.” Id.

at 45:19. Childers then emerged from the other bedroom. See id. at 32:2–10. There

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