The North Dakota Supreme Court convened on January 11, 2025, to discuss the case of State v. Henderson, focusing on the legal concept of constructive possession in relation to drug paraphernalia found during a search. The central issue revolved around whether the state had provided sufficient evidence to demonstrate that the defendant exercised dominion and control over the paraphernalia discovered in a kitchen cupboard.

During the proceedings, the defense argued that the evidence presented by the state was inadequate. They highlighted that the defendant was not present in the kitchen at the time of the search, as he was located in the garage, which undermined claims of proximity. The defense pointed out that the paraphernalia was not in plain view and that the state’s argument regarding the defendant's mail being near the contraband did not establish his presence or control over the items.

The discussion referenced previous cases, including State v. Morris and State v. Dimowski, which outline a three-part analysis for determining constructive possession. This analysis considers the location of the contraband, the proximity of the defendant to that location, and whether the items were in plain view. The defense contended that none of these factors were satisfied in Henderson's case, emphasizing that the state failed to prove a direct connection between the defendant and the paraphernalia.

The court also noted that the state had listed multiple individuals in connection with the paraphernalia, further complicating the assertion of possession. The defense maintained that without clear evidence of dominion and control, the district court's ruling in favor of the state was erroneous.

In conclusion, the Supreme Court's deliberation highlighted significant legal principles regarding constructive possession and the burden of proof required for such cases. The outcome of this case could have implications for future rulings on similar matters, particularly concerning the standards of evidence necessary to establish possession of contraband.