The Louisiana Supreme Court reversed the conviction and sentences of Gerald Manchip White, who was found guilty of possessing firearms as a convicted felon after guns were discovered in his family home. The court ruled that the evidence was insufficient to prove White had the requisite intent for constructive possession of the firearms.
In a decision issued Dec. 11, 2025, Justice Guidry wrote for the majority in *State of Louisiana v. Gerald Manchip White* (La. 2025), finding that the jury's verdict was not supported by adequate evidence to establish constructive possession.
The case stemmed from charges filed after parole officers discovered three guns in White's residence, which he shared with family members. White faced three counts of possession of a firearm by a convicted felon following the discovery.
The events leading to White's charges began when parole officer Ayleen Cook visited his home two days before the guns were found. Cook was initially searching for another individual but spoke with White during her visit. During this conversation, White informed Cook about a recent home invasion incident.
According to court records, White told Cook that an intruder had invaded the home approximately two weeks earlier. During the robbery, the intruder shot White's son Jordan using Jordan's own gun. When Cook asked whether the gun remained in the house, White confirmed it was still there.
Cook reminded White that as a convicted felon, he could not have guns in his residence and told him "it must be removed." The warning proved significant to the case's outcome, as it demonstrated White's awareness of the legal prohibition.
Two days after this initial contact, Cook returned to White's residence with additional parole officers, including White's assigned officer, Erikka Smith. The officers conducted a residence check during which they discovered the firearms that became the basis for the charges against White.
The Louisiana Supreme Court's analysis focused on the legal standard for constructive possession, which requires proof that a defendant had both knowledge of the firearm's presence and the intent to possess it. Unlike actual possession, where someone physically holds an object, constructive possession involves having control over an item without direct physical contact.
The court examined whether the State had presented sufficient evidence to prove White intended to possess the firearms found in his home. This determination was crucial because mere presence of firearms in a residence shared with family members does not automatically establish constructive possession by a convicted felon.
Justice Guidry's majority opinion concluded that the evidence failed to meet the burden of proof required for conviction. The court found that the State had not adequately demonstrated White's intent to possess the firearms, a necessary element for establishing constructive possession.
The decision was not unanimous. Chief Justice Weimer filed an additional concurrence with assigned reasons, while Justice Cole also filed a separate concurrence. However, Justices Crain and McCallum dissented from the majority's ruling. Justice Crain wrote a dissenting opinion, and Justice McCallum joined that dissent.
The case highlights the complex legal issues surrounding constructive possession charges, particularly in situations involving shared residences. For convicted felons, the presence of firearms in their homes can lead to serious criminal charges even if they do not directly handle the weapons.
The Supreme Court's reversal overturns both White's convictions and sentences on all three counts. The decision establishes important precedent for how Louisiana courts should evaluate evidence in constructive possession cases involving firearms.
Constructive possession cases often present challenges for prosecutors, who must prove not only that a defendant knew about the presence of contraband but also that they intended to exercise control over it. The burden becomes more complex in family settings where multiple individuals have access to the same spaces.
The ruling may impact similar cases throughout Louisiana, as it clarifies the evidentiary standard required for constructive possession convictions. Defense attorneys representing clients in similar situations may cite this decision when arguing that mere proximity to firearms is insufficient for conviction.
The case originated in Bossier Parish and went through the Court of Appeal, Second Circuit, before reaching the Louisiana Supreme Court on a writ of certiorari. The Supreme Court's decision to grant review and ultimately reverse the conviction demonstrates the significance of the legal issues involved.
White's case underscores the importance of intent in criminal law, particularly for possession offenses involving convicted felons. The court's emphasis on the insufficient evidence of intent provides guidance for future prosecutions and defenses in similar cases throughout the state.