## Facts

- A motel manager contacted police about “hippie-type people” using a motel room registered in Harold Eugene Valot, Jr.’s name.
- Police recognized Valot’s name as that of an escapee from the Detroit House of Correction.
- With the manager’s assistance, officers entered the room and found five people sleeping, including Valot, and arrested Valot.
- Officers observed a strong odor of marijuana and, in plain view, hand-rolled marijuana cigarettes, paraphernalia (including a water pipe on a table next to Valot’s bed), and marijuana cigarette butts on the floor (including one next to Valot’s bed).
- Valot testified he knew another occupant used marijuana and claimed he was unaware marijuana was present in the room.
- After a bench trial, Valot was convicted under a statute prohibiting having “possession or control” of marijuana; the trial court’s finding rested on “control” rather than physical possession.

## Issues

1. Whether police entry into the motel room and seizure of marijuana violated constitutional protections against unreasonable searches and seizures.
2. Whether the evidence was sufficient to prove Valot had “possession or control” of the marijuana, despite his claim that it belonged to others and he lacked knowledge.
3. Whether a circumstantial-evidence case requires the prosecution to exclude all reasonable hypotheses consistent with innocence.

## Decision

- The Michigan Court of Appeals affirmed the conviction.
- The entry and seizure were lawful because officers had a valid basis to enter to arrest an escapee and seized contraband observed in plain view incident to a lawful arrest.
- The evidence was sufficient for the fact-finder to infer Valot’s control over the marijuana from his rental and dominion over the room, his presence, and the proximity and obvious presence of marijuana and paraphernalia.
- The court rejected a rule requiring the prosecution to exclude all reasonable hypotheses consistent with innocence in circumstantial cases.

## Legal Principles

- A narcotics statute prohibiting “possession or control” permits conviction based on constructive possession/control shown by dominion over premises and circumstances connecting the defendant to contraband, even without manual possession.
- Contraband discovered in plain view may be seized when officers are lawfully present, including during a lawful arrest.
- Circumstantial evidence can support a criminal conviction; the proper inquiry is whether the evidence permits guilt beyond a reasonable doubt, not whether the prosecution has negated every reasonable innocent explanation.
- Appellate review defers to the trial court’s credibility determinations and reasonable inferences drawn from the evidence in a bench trial.

## Conclusion

The court upheld Valot’s marijuana conviction, holding that police lawfully entered to arrest him and seized contraband in plain view, and that circumstantial evidence—especially his rental of and presence in a room permeated with marijuana and paraphernalia near his bed—supported a finding that he knowingly exercised “control” over the marijuana.


People v. Valot, 33 Mich. App. 49, 189 N.W.2d 873 (Mich. Ct. App. 1971)