What is the sufficiency of evidence to prove constructive possession?

We review the sufficiency of evidence to determine whether "a reasonable jury, after viewing the evidence in the light most favorable to the government, could have found the defendants guilty beyond a reasonable doubt of each essential element of the crime charged." United States v. Hernandez, 876 F.2d 774, 777 (9th Cir.), cert. denied, 493 U.S. 863 (1989).

"To prove a conspiracy, the government must show (1) an agreement (2) to engage in criminal activity and (3) one or more overt acts in furtherance of the conspiracy." Hernandez, 876 F.2d at 777. The agreement can be implied from the facts and circumstances of the case. Id. To prove constructive possession, the government must show that the defendant had " 'sufficient dominion and control to give him the power of disposal....' " Id. at 778 (quoting United States v. Castillo, 866 F.2d 1071, 1086 (9th Cir.1989)). Circumstantial evidence can establish both knowledge and possession. Id. A defendant's participation in a joint venture to distribute a controlled substance is sufficient to establish constructive possession. Id. (citing United States v. Moreno, 649 F.2d 309, 313 (5th Cir.1981) (evidence sufficient to show constructive possession where the defendant "enjoyed a close and continuous working relationship with those ... who may have had actual physical possession of the marijuana")).