Stash House Search Warrant Lessons: Making the Firearm Charge Stick

Scott Courrege
3 hours ago
4 min read

United States v. Jones

Citation: United States v. Jones, No. 24-4282, ___ F.4th ___ (4th Cir. Feb. 4, 2026)

TL;DR

The Fourth Circuit affirmed Lawrence Jones’s firearm convictions, holding that sufficient circumstantial evidence supported a finding of constructive possession of firearms discovered inside a drug stash house. Even without fingerprints, eyewitness testimony, or exclusive control of the premises, the totality of the evidence allowed the jury to reasonably conclude that Jones knowingly possessed the guns.

Why it matters: This decision reinforces how little direct evidence is required to sustain firearm convictions when guns are found in close proximity to drugs inside a stash house.

Limits: Constructive possession remains a fact-specific inquiry; proximity alone is not enough without additional indicia of dominion, control, and knowledge.

Facts

Raleigh police identified a residence as a drug stash house during a broader narcotics investigation. Surveillance and wiretaps showed Lawrence Jones frequently visiting the residence whenever he was in North Carolina. Jones coordinated large-scale drug trafficking activity involving cocaine and marijuana, with drugs moving between California and North Carolina.

When officers executed a search of the stash house after Jones’s arrest, they discovered cocaine throughout the residence. In the front bedroom, officers found a bag of cocaine on top of the bed, two loaded firearms hidden between the mattress and box spring, a firearm box in plain view next to the bed, and more than $95,000 in cash under the bed.

Jones’s personal documents were found inside the residence, and evidence showed that he exercised joint control over the stash house. Officers later recovered ammunition matching the firearms from a location associated with one of Jones’s girlfriends.

A jury convicted Jones of possession of a firearm in furtherance of a drug trafficking crime and possession of a firearm by a felon.

Issue

Was the evidence sufficient to prove that Jones possessed the firearms found in the stash house?

Holding

Yes. The Fourth Circuit held that the evidence was sufficient to support both firearm convictions.

Reasoning

Constructive Possession Controls

Possession of a firearm may be actual or constructive. Constructive possession exists when a defendant exercises, or has the power to exercise, dominion and control over the firearm or over the premises where it is located, coupled with knowledge of the firearm’s presence.

The court emphasized that constructive possession is evaluated through a fact-specific, totality-of-the-circumstances analysis. While proximity alone is insufficient, proximity combined with other incriminating evidence may support a conviction.

Evidence Supporting Possession

Here, multiple facts supported the jury’s verdict:

Jones exercised joint control over the stash house and visited it frequently.
Personal documents belonging to Jones were found inside the residence.
Drugs, firearms, and cash were all located together in the same bedroom.
The firearms were hidden inches from cocaine and cash, not in a remote or inaccessible area.
A firearm box was in plain view near the bed.
Ammunition matching the firearms was recovered from a location tied to Jones.

Taken together, this evidence permitted the jury to reasonably infer that Jones knew the firearms were present and possessed them in furtherance of his drug trafficking activity.

What the Government Did Not Need

The Fourth Circuit rejected the argument that the government needed fingerprints, DNA, eyewitness testimony, or exclusive control of the residence. The absence of direct evidence did not undermine the verdict where the circumstantial evidence, viewed as a whole, supported constructive possession.

Defense Arguments That Failed

Jones raised several common defense themes often seen in stash-house firearm cases, but the Fourth Circuit rejected each one.

“No one saw him with a gun.” The court reiterated that eyewitness testimony is not required. Constructive possession may be proven entirely through circumstantial evidence, especially when firearms are discovered in close proximity to drugs and cash.

“There were no fingerprints or DNA.” The absence of forensic evidence did not undermine the verdict. The Fourth Circuit emphasized that the government is not required to present fingerprints, DNA, or ballistic testing where the surrounding facts reasonably establish knowing possession.

“He didn’t exclusively control the house.” Joint control of a stash house does not defeat possession. The court made clear that shared access only means the government must present additional evidence of dominion, control, and knowledge—which it did here.

“Someone else could have put the guns there.” Speculative alternative explanations are insufficient on appeal. When the evidence permits a reasonable inference of guilt, the jury—not the appellate court—decides which inference to credit.

“Proximity alone isn’t enough.” While true as a general rule, proximity combined with other incriminating facts—such as visibility, accessibility, and linkage to drug trafficking—was more than sufficient in this case.

Street Takeaways

Firearms hidden in stash houses are rarely accidental.
Drugs + guns + cash in the same room is powerful evidence of possession.
Joint control of a residence does not shield a defendant from firearm liability.
Constructive possession cases live and die on context, not fingerprints.
Officers should carefully document proximity, visibility, and access when firearms are recovered during drug searches.