Appellate Court Reviews Vehicle Gun Possession Evidence Standards in Thompson v. State

As we delve into the intricacies of Maryland criminal law, certain cases emerge that significantly impact how we understand fundamental legal concepts.

The recent decision in Thompson v. State, No. 1542, Sept. Term, 2023, slip op. at ___ (Md. App. Jan. 2, 2025) (unreported) offers us a fascinating lens through which to examine how Maryland appellate courts analyze the sufficiency of evidence in criminal cases regarding knowledge and constructive possession.

Click this safe link to download the Thomspon v. State (2025 case.

Thompson v. State, No. 1542, Sept. Term 2023 (Md. App. Jan. 2, 2025)

Note: This opinion is unreported and may not be cited as precedent or persuasive authority under Maryland Rule 1-104.

Case Facts

When law enforcement conducted a lawful traffic stop, Seana R. Thompson was driving her vehicle with a front-seat passenger on an unspecified date.

During the stop, police officers performed a search of the vehicle, leading to the discovery of a handgun. According to the appellate opinion, the firearm was found “in a bag located on the floorboard of the driver’s rear side . . . in the middle of two food containers in the bag.”

As the driver of the vehicle, Thompson was questioned by law enforcement.

During the interaction, police body-worn camera footage recorded Thompson referring to the car as hers and mentioning that she had a hoodie “in the back.” At the time of the stop, no other individuals were seated in the backseat.

Following the search, Thompson was charged with knowingly transporting a handgun in a vehicle in violation of Md. Code Ann., Crim. Law (“CR”) § 4-203(a)(1)(ii).

The case proceeded to trial in the Circuit Court for Prince George’s County, where a jury found Thompson guilty.

The Court sentenced her to two years of incarceration, with all but time served suspended, followed by two years of supervised probation.

Thompson subsequently appealed her conviction, arguing that the State failed to present sufficient evidence to establish that she had knowledge of the handgun in her vehicle.

The primary question before the Appellate Court of Maryland was whether a rational fact-finder could infer Thompson’s knowledge of the handgun based on the evidence presented at trial.

Thompson’s Appeal: The Knowledge Element Challenge

On appeal, Thompson argued that the State failed to prove she knowingly transported a handgun in her vehicle, as required by Md. Code Ann., Crim. Law § 4-203(a)(1)(ii).

Her challenge centered on the knowledge element — whether the evidence was sufficient to establish that she was aware of the handgun’s presence.

The case was not about physical possession alone; instead, it tested the limits of constructive possession and the prosecution’s burden to prove intent.

Understanding The Appellate Court’s Legal Framework

The Court’s Standard of Review

In reviewing Thompson’s conviction, the Court applied the sufficiency of the evidence standard, a deferential test that limits appellate intervention in jury verdicts.

Citing Williams v. State, 251 Md. App. 523 (2021), the Court framed the question as whether “any rational trier of fact could have found the essential elements of the crimes beyond a reasonable doubt.”

This standard is significant because:

• It does not assess whether most fact-finders would have reached the same conclusion.
• It asks only whether any rational fact-finder could have done so.
• It requires the evidence to be reviewed in the light most favorable to the State.

The Statutory Framework

To sustain a conviction under Md. Code Ann., Criminal Law § 4-203(a)(1)(ii), the State was required to prove that Thompson “knowingly transported” a handgun in her vehicle.

The knowledge element became the focal point of Thompson’s appeal; she contended the State failed to establish that she was aware of the firearm’s presence.

The Appellate Court of Maryland’s Court’s Analysis

The Driver Status Doctrine

The Court’s analysis rested on a key principle from State v. Smith, 374 Md. 527 (2003): A driver’s status alone permits an inference of knowledge of contraband in the vehicle.

The Court reaffirmed that this inference applies regardless of whether the driver owns, leases, or is merely operating the vehicle.

Citing Smith, the Court stated:

“[Whether a driver] actually own[s], [is] merely driving, or [is] the lessee of the vehicle, permit[s] an inference, by [the jury], of knowledge, by [the driver], of contraband found in that vehicle.” Thompson (2025) (quoting Smith, 374 Md. at 550).

This doctrine reflects Maryland’s long-standing approach to constructive possession: drivers are presumed to know what is inside their vehicles unless there is strong evidence to the contrary.

Thompson challenged this presumption, arguing that the State failed to provide additional evidence linking her to the handgun.

However, the Court emphasized that no additional factors are strictly required beyond the defendant’s role as a driver to permit an inference of knowledge.

Supporting Evidence That Strengthened the Inference of Knowledge

While the driver status doctrine was the foundation of the Court’s analysis, the opinion identified additional factors that reinforced the jury’s conclusion that Thompson knew about the firearm:

• Thompson asserted ownership over the vehicle, reinforcing the presumption that she knew its contents.
• She specifically referenced having personal belongings in the backseat, where the handgun was found.
• The firearm was located on the floorboard behind the driver’s seat, within easy reach.
• There were no backseat passengers, reducing the likelihood that someone else placed the firearm there without her knowledge.

By considering these circumstantial factors, the Court found that a rational jury could conclude Thompson knowingly transported the handgun.

The Role of Circumstantial Evidence

The Court also reaffirmed that circumstantial evidence carries the same weight as direct evidence in establishing guilt.

It relied on Maryland precedent to emphasize that a conviction may rest entirely on circumstantial evidence so long as a rational fact-finder could infer guilt beyond a reasonable doubt. Thompson (2023) (citing Smith v. State, 415 Md. 174, 185–86 (2010)).

In evaluating Thompson’s case, the Court noted that the totality of circumstances supported the inference of knowledge, even if no direct evidence proved that she physically handled the gun.  

Th Court’s Holding & Outcome

The Court affirmed Thompson’s conviction, holding that the evidence was sufficient for a rational jury to conclude that she knowingly transported a handgun in her vehicle, as required under Md. Code Ann., Crim. Law § 4-203(a)(1)(ii).

In reaching its decision, the Court emphasized:

• The driver status doctrine — permits an inference that the driver of a vehicle is aware of its contents.
• Thompson’s own statements — she identified the vehicle as hers and referenced having personal belongings in the backseat, linking her to the area where the handgun was found.
• The handgun’s location — placed on the rear floorboard behind the driver’s seat, within easy reach.
• The absence of backseat passengers — eliminates a potential alternative explanation for the firearm’s presence.

The Court reiterated that no additional evidence beyond a defendant’s status as a driver is required for a jury to infer knowledge of contraband in the vehicle.

However, additional factors further supported the inference.

Accordingly, the Court concluded:

“Thus, the evidence, when viewed in the light most favorable to the State, was sufficient to sustain Thompson’s conviction.”  

The judgment of the Circuit Court for Prince George’s County was affirmed, and Thompson was ordered to pay the appeal’s costs.

Practical Takeaways & Legal Impacts

For Legal Practitioners

This decision reinforces critical legal considerations for both defense attorneys and prosecutors handling constructive possession cases:

• Defense attorneys should challenge the driver status inference early, particularly when there is minimal evidence beyond the defendant’s role as a driver.
• Prosecutors should bolster the inference by presenting additional factors — such as statements by the defendant, the proximity of the contraband, and the absence of alternative occupants.
• Judges should be mindful of whether the totality of circumstances supports a jury’s inference of knowledge, particularly in cases relying heavily on circumstantial evidence.

This case underscores the importance of vehicle configuration and passenger placement in constructive possession analyses.

Defense attorneys may argue that proximity alone does not establish knowledge, while prosecutors can emphasize accessibility and ownership statements to strengthen their case.

For Law Enforcement

The decision offers key guidance for police officers conducting traffic stops and vehicle searches:

• Thoroughly document vehicle occupancy — noting all passengers’ locations is crucial in establishing (or refuting) constructive possession.
• Record statements regarding vehicle ownership — comments made by the driver can strengthen or weaken the State’s case.
• Clearly describe where contraband is found — proximity to the driver and accessibility can be pivotal in Court.

Proper documentation can significantly impact whether an appellate court finds sufficient evidence to support a conviction.

For Maryland Residents & Criminal Defendants

Maryland drivers should take note:

• Being the driver alone can create severe legal exposure. Even if you were unaware of contraband in your vehicle, you may still be legally presumed to know about it.
• Statements about vehicle ownership carry weight. If you claim ownership of a vehicle or reference belongings inside, you may strengthen the State’s inference of knowledge.
• The location of contraband matters. If an item is within reach of the driver’s seat, a jury may infer that the driver knew of its presence.

This case warns that ignorance of an item’s presence in a vehicle may not always be a viable defense.

The Evolution of Possession Law in Maryland

Historical Context

To fully understand Thompson v. State (2025), viewing it within the broader evolution of Maryland possession law is essential.

• Smith v. State, 374 Md. 527 (2003) established the driver status doctrine, holding that a driver’s presence in a vehicle permits an inference of knowledge of contraband.
• Gimble v. State, 198 Md. App. 610 (2011) reinforced this principle while adding that additional factors — such as flight—can strengthen the inference of knowledge.

Implications & Future Considerations

Thompson v. State (2023) is more than a routine possession case.

It exemplifies how Maryland courts interpret the sufficiency of evidence, apply legal presumptions, and navigate the complexities of constructive possession in criminal law.

This decision reinforces the driver status doctrine while illustrating how appellate courts assess circumstantial evidence without direct proof.

It provides a valuable precedent for attorneys, judges, and law enforcement officers when evaluating knowledge-based possession cases.

Beyond its immediate impact, Thompson raises broader questions about the future of possession law:

• How will courts handle shared vehicle situations where multiple individuals have access to a car?
• Could evolving vehicle technologies—such as smart cars, rental tracking, and rideshare apps—affect how courts infer knowledge of contraband?

As Maryland criminal law adapts to modern transportation realities, cases like Thompson’s will continue shaping the contours of Maryland’s constructive possession doctrine.

Referenced Statutory Authority & Case Law 

This section compiles the Maryland case law and statutory provisions cited by the Appellate Court of Maryland in Thompson v. State (2025), providing context on how courts analyze constructive possession and sufficiency of evidence in criminal cases.

Maryland Statutes Cited in Thompson v. State

• Md. Code Ann., Criminal Law § 4-203(a)(1)(ii)

  • Unlawful Transportation of a Handgun
  • Prohibits individuals from knowingly transporting a handgun in a vehicle without legal justification.
  • The knowledge element in this statute was the core issue in Thompson, as the appellant argued the State failed to prove she was aware of the handgun’s presence.

• Maryland Rule 1-104

  • Precedential Value of Unreported Opinions
  • Declares that unreported opinions, like Thompson’s, are not precedent and may not be cited as persuasive authority in future cases.

Maryland Case Law Cited

• Williams v. State, 251 Md. App. 523, 569 (2021)

  • Standard of Review for Sufficiency of Evidence
  • Established that appellate courts review evidence in the light most favorable to the State and assess whether any rational fact-finder could have found the essential elements beyond a reasonable doubt.

• Smith v. State, 232 Md. App. 583 (2017)

  • Clarification of the “Any Rational Trier of Fact” Standard
  • Reiterated that sufficiency review does not consider whether the evidence would persuade most jurors — only whether it could persuade any rational juror.

• State v. Smith, 374 Md. 527 (2003)

  • The Driver Status Doctrine
  • Held that a driver’s presence in a vehicle permits an inference that they know about contraband inside the vehicle, regardless of ownership.
  • The Court in Thompson relied on this as the foundation for constructive possession.

• Gimble v. State, 198 Md. App. 610 (2011)

  • Strengthening Constructive Possession Inferences
  • Found that additional factors, such as flight from law enforcement, can strengthen a jury’s inference of knowledge of contraband inside a vehicle.

• Smith v. State, 415 Md. 174, 185–86 (2010)

  • Circumstantial Evidence in Sufficiency of Evidence Cases
  • Confirmed that circumstantial evidence is not inherently weaker than direct evidence and can support a criminal conviction.

Join the Conversation

How should Maryland courts approach knowledge-based possession cases in the context of rideshare vehicles, rental cars, or autonomous driving technology?

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