The Shotgun by the Bed

Police obtained a warrant on the strength of information that the Accused's son was in unlawful possession of firearms, and executed it at a residence. They found four loaded firearms. A .357 Magnum revolver was under a pillow on the master bedroom bed. A 12-gauge shotgun stood propped against the wall beside the bed, in plain view. Two more firearms were in an apparently uninhabited basement bedroom. The Accused's identification was in the nightstand next to the bed and his passport was in the bedroom closet. He faced four counts of possessing a loaded prohibited or restricted firearm. He attacked the search warrant, and separately raised an argument about one particular count - the one relating to the shotgun, which was neither a prohibited nor a restricted firearm. The Crown maintained that a loaded shotgun leaning against the bed of a man whose identification sat in the nightstand beside it was possession, plainly proved.