The Court of Appeals on a second remand on August 20, 2015, in LIHLAKHA v. U.S., clarifies further the return for reward defense for receiving stolen property (RSP) conviction. Lihlakha was convicted at trial for RSP and her defense and arguments on appeal focused on return for reward defense. The Court on the first review outlined for the first time the elements needed to successfully assert the defense: Specifically, the defense will be satisfied if the evidence shows that: “(1) The reward had been announced, or was believed to have been announced, before the property was possessed or agreed to
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