Flight and Suspicious Goods Does Not Receipt of Stolen Property Make

Williams v. United States (Decided March 23, 2017)

The Players: Associate Judges Glickman and Beckwith, and Senior Judge Belson. Opinion by Judge Belson. Trial Judge Ann O’Regan Keary. Anna B. Scanlon for Mr. Williams.

Facts: At 4:00 AM, Officer Steven Good encountered a group of men, including Williams. He made eye contact with Williams, who then nudged a backpack at his feet, as if to conceal it. Good then asked the men if they would speak with him, at which point the group took off running. Good’s partner pursued Williams and found him lying down along an air-conditioning unity, holding a backpack.

Inside the backpack was a single bullet, a wallet, some jewelry and watches, and four ID cards. Good recognized the cards as matching the faces and names of a different group of men who had approached him at 10:30 the evening before and asked to use his phone. Later, Williams told Good, in reference to another member of the group that was apprehended, “He had nothing to do with it. You can let him go. I did it all on my own.”

Neither testimony from the owners of the IDs, nor the IDs themselves were offered at trial. The only detail provided about the IDs was that they bore names and photographs, but there was no information as to what kind of IDs they were, or whether they were expired or valid. Hearsay testimony that the men who had asked to use Good's phone the evening before said they had been robbed was excluded.

Based on this evidence, the trial court found Williams guilty of receiving stolen property, reasoning that the combination of William’s flight, his apparent concern specifically about the backpack, and the fact that the IDs matched individuals who had asked Good for assistance on the previous evening supported a reasonable inference that the IDs were stolen.

Issue: Was there sufficient evidence to support reasonable inferences that the ID cards were stolen and that Williams knew they were stolen?

Holding: No. Because the IDs were not reported stolen, the trial court had to rely on an inference that such a theft indeed occurred. But, “[t]he evidence did not eliminate other scenarios under which the identification cards might have come into appellant’s possession, including other scenarios which could have left appellant with a consciousness of guilt.” While William’s behavior suggested some consciousness of guilt, the crucial missing piece of the puzzle was “guilty of what.” 

CP

Read full opinion here