The Court of Appeals in Williams v. United States decided on March 23, 2017, reversed the conviction for receiving stolen property and remanded the case to the trial court.

The underlying facts were that four men had approached a police office to borrow his phone to and to report a robbery. The next day the same officer detained and searched the defendant who was found in possession of four identification cards that matched the same four men who had approached the officer earlier.

The trial court found the circumstantial evidence to be compelling enough to warrant the conviction. Specifically, the trial court reasoned: “The fact [] that defendant having in his possession multiple I.D.’s of other persons who turn out to be the same individuals who had approached the police officer for assistance earlier in the evening is strong circumstantial evidence supporting a finding that these I.D.’s had been stolen.”

The legal elements of receiving stolen property are:

1. One is guilty of the offense if the person buys, receives, possesses or obtains control of;
2. The stolen property;
3. Knowing or having reason to believe that the property was stolen and that;
4. The property has some residual value.

The Court of Appeals disagreed with the trial court in finding the evidence to be persuasive but not compelling beyond a reasonable doubt. That is “a finder of fact is not permitted to cross the bounds of permissible inference and enter into the forbidden territory of conjecture and speculation.”

The specific evidence considered by the trial court were:

1. Four men approached Officer Good asking to use his phone and provided him with their names;
2. The names and faces of the individuals who approached the officer matched those on the identification cards eventually found in appellant’s backpack;
3. Subsequently, appellant, after making eye contact with the officer, started to nudge a backpack;
4. Appellant ran when he was approached by the officer;
5. Appellant was found lying next to an air-conditioning unit and clutching the backpack;
6. Identification cards, jewelry, watches, a wallet, and a bullet were found in the backpack, and
7. After his arrival at the police station, appellant made the statement regarding the other man who had run from the officer, “He had nothing to do with it. You can let him go. I did it all on my own.”
8. There was no reporting or witness who testified that the identification cards in questions were in fact stolen. Such direct evidence and link was necessary to sustain a conviction for receiving stolen property.

The Court further expounded that acting guilty is not tantamount to being guilty of a crime sustaining a conviction.

Contact our Washington DC Criminal Lawyer/DC Theft lawyer today for free initial consultation.