See Robinson v. United States , 100 A.3d 95, 105 n.16 (D.C. 2014) ("Our cases have defined "actual possession" as the ability of a person to knowingly exercise direct physical custody or control over the property in question .... Constructive possession likewise entails knowledge of the location of the item, as well as the ability and intention to exercise dominion and control over it." (alteration in original) (internal quotation marks and citations omitted)); see also White v. United States , 714 A.2d 115, 118 & n.5 (D.C. 1998) (where case went to the jury on both actual and constructive theories of "carrying," "conviction [from general verdict] may be affirmed if the evidence was sufficient to support either theory").See Criminal Jury Instructions for the District of Columbia, No. 6.

Brief for Appellant at 9 (quoting Rivas v. United States , 783 A.2d 125, 134 (D.C. 2001) (en banc) ).In fact, we have held that the evidence was sufficient to infer actual possession on facts quite similar to those presented here. See, e.g. , In re A.L. , 839 A.2d 678, 680 & n.5 (D.C. 2003) (evidence sufficient to infer actual possession of drugs when arresting officer testified he saw juvenile defendant holding shiny object officer believed to be a plastic bag run into stairwell to avoid police officers who later recovered from drainpipe in stairwell a plastic bag containing marijuana); White v. United States , 714 A.2d 115 (D.C. 1998). In White , an MPD officer recovered a gun from a box in the back of an ice-cream truck.

Zanders v. United States, 75 A.3d 244 (D.C.2013).Id. at 251 (citing Smith, 899 A.2d at 123 (knees holding glove compartment shut to conceal gun)); Williams v. United States, 884 A.2d 587, 604 (D.C.2005) (knocking bag of chips to floor to conceal gun); White v. United States, 714 A.2d 115, 119 (D.C.1998) (reaching into box that concealed firearm).The foregoing decisions, illustrating “something more” based on “movement or gesture in front of the police,” leave room, of course, for other indicia of intent, as illustrated above in the block quotation from Rivas . This case carries us into alleged indicia of intent other than overt movement or gesture.

McDuffie testified that to sell drugs as a member of the 22nd Street Crew:See White v. United States, 714 A.2d 115, 119 n. 5 (D.C.1998) (“Since the jury returned a general verdict of guilty on the charge ..., the conviction may be affirmed if the evidence was sufficient to support either theory.”).

Although our cases have not always been clear on this point, the requirement that a gun be “convenient of access and within reach” is a component of offenses involving “carrying on or about the person,” not of offenses involving the broader concept of possession. See, e.g., White v. United States, 714 A.2d 115, 119–20 (D.C.1998) (“ ‘possession’ is a broader concept than to ‘carry on or about the person’ ”; to establish carrying, “the government's evidence must go beyond mere proof of constructive possession and must show that the pistol was in such proximity to the person as to be convenient of access and within reach”) (internal quotation marks omitted); Halicki v. United States, 614 A.2d 499, 503 n. 9 (D.C.1992) (court has occasionally equated concepts of “carrying” and “possession” without discussing whether concepts are in fact same). Because Mr. Evans was convicted of possessory offenses, the evidence need not have established that the guns were convenient of access and within reach.

However, this court has previously read the term “carry” under § 22–4504 to include “actual possession of the gun.” White v. United States, 714 A.2d 115, 118–19 (D.C.1998). “[A]ctual possession” is defined as “direct physical control over an object at a given moment.”

Smith, 899 A.2d at 122. Thus, for example, we have found constructive possession of a firearm when the defendant kept his knees against the door of the glove compartment to keep a gun from falling out, Smith, 899 A.2d at 123; when the defendant reached into a box that was later found to contain the firearm, ( Mischell) White v. United States, 714 A.2d 115, 119 (D.C.1998); and when the defendant moved his hand toward a handgun and knocked a bag of chips to the floor to conceal the butt of the gun, Williams v. United States, 884 A.2d 587, 604 (D.C.2005). Appellant correctly notes that this court has “reject[ed] any presumption that contraband in plain view in an automobile is sufficient by itself to show that a passenger intended to control it.” Rivas, 783 A.2d at 143 (Ruiz, J., concurring).

.D.C.Code § 22–4504(a) (providing that “[n]o person shall carry within the District of Columbia either openly or concealed on or about their person, a pistol, without a license ... or any deadly or dangerous weapon capable of being so concealed”). See, e.g., White v. United States, 714 A.2d 115, 119 (D.C.1998) (emphasis added) (quoting Brown v. United States, 58 App.D.C. 311, 312, 30 F.2d 474, 475 (1929)). See, e.g.,Webster's Third New International Dictionary 150 (definition of “available”), 1889 (definition of “readily”) (2002 ed.).

; People v. Dunaway, 88 P.3d 619, 631 (Colo. 2004) (upholding conviction where only one alternative theory of liability for a child abuse charge was supported by the evidence beyond a reasonable doubt); White v. United States, 714 A.2d 115, 118 n. 5 (D.C. 1998) (holding that, since the jury returned a general verdict of guilty on the charge of carrying a concealed weapon, the conviction may be affirmed if the evidence was sufficient to support either theory of liability-actual possession or constructive possession); San Martin v. State, 717 So. 2d 462, 469 (Fla. 1998) (holding that murder conviction was valid even though evidence was insufficient on theory of premeditated murder, because evidence was sufficient for felony murder theory); Commonwealth v. Candelario, 848 N.E.2d 769, 778 (Mass. 2006) (holding that the issue of the sufficiency of evidence to support a theory of murder with extreme atrocity or cruelty was moot where there was no dispute that evidence was sufficient to support the alternative theory of deliberate, premeditated murder); People v. Ponnapula,655 N.Y.S.2d 750, 760 (N.Y. 1997) ("[W]hen disjunctive theories of criminality are submitted to the jury and a general verdict of guilt is rendered, a challenge based on evident

The trial court instructed the jury on constructive possession, that is, that Jones carried the pistol "about" his person. See White v. United States, 714 A.2d 115, 119 (D.C. 1998). To establish constructive possession as to the latter two charges, the government had to prove, by direct or circumstantial evidence, that Jones knew of the existence of the gun and had both the ability and intent to exercise dominion and control over it. Rivas v. United States 783 A.2d 125, 129 (D.C. 2001) (en banc).