State v. McDowell

TERNUS, Justice

(concurring specially).

I concur in the court’s opinion for two reasons. First, our opinion signals the court’s return to a proper application of the principles of constructive possession as set forth in State v. Reeves, 209 N.W.2d 18 (Iowa 1993). Secondly, our opinion implicitly rejects the erroneous application of those principles made in State v. Simpson, 528 N.W.2d 627 (Iowa 1995).