People v. Canadian Fur Trappers Corp.
248 N.Y. 159, 161 N.E. 455, 59 A.L.R. 372 (1928)
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Rule of Law:
A corporation can be held criminally liable for a specific intent crime, such as larceny, if the criminal intent can be attributed to the corporation itself. This corporate intent may be proven by evidence that the criminal acts were authorized by the corporation's officers or that the acts were so methodical and continuous as to indicate the sanction of the corporation.
Facts:
- Canadian Fur Trappers Corporation, operating as 'Fields' and owned by the four Dornfeldt brothers, sold fur coats on an installment plan.
- A customer, Mrs. Ella Stanley, purchased a coat for $295, making a $25 deposit.
- The corporation agreed to store the specific coat for Mrs. Stanley until she paid the balance.
- The purchase slip included a guarantee for free storage and insurance against fire and burglary.
- When Mrs. Stanley returned to pay the remaining balance, her coat was missing.
- The corporation's employees attempted to give her a different coat of another size and make.
- The substitute coat offered to Mrs. Stanley had previously been sold to another customer, Vera M. Owen.
Procedural Posture:
- The People of the State of New York prosecuted Canadian Fur Trappers Corporation for grand larceny, second degree, in the County Court.
- A jury found the corporation guilty.
- The corporation, as appellant, appealed the conviction to the Appellate Division of the Supreme Court.
- The Appellate Division affirmed the trial court's judgment of conviction.
- The corporation, as appellant, then appealed to the Court of Appeals of New York, the state's highest court.
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Issue:
Can a corporation be convicted of grand larceny, a crime that requires a specific criminal intent to steal?
Opinions:
Majority - Crane, J.
Yes, a corporation can be convicted of grand larceny. While the old doctrine held that a corporation could not form criminal intent, modern law recognizes that a corporation can be criminally liable for the acts of its agents. For specific intent crimes like larceny, the intent to steal must be that of the corporation itself, not merely that of its agent. This corporate intent can be established by proving that the criminal acts were either authorized by corporate officers or were part of a continuous and methodical practice so ingrained as to imply corporate sanction. In this case, the trial court correctly instructed the jury on this standard but then erroneously excluded evidence that would have shown the defendant had a regular business practice of reselling coats held on deposit. Because the prosecution was prevented from proving this corporate-sanctioned practice, the evidence admitted at trial was insufficient to support the conviction, necessitating a new trial.
Analysis:
This case is significant for firmly establishing that corporate criminal liability extends beyond regulatory offenses to include crimes requiring specific intent (mens rea). It moves away from the legal fiction that a corporation, as an artificial entity, cannot form a 'guilty mind.' The court's analysis provides a practical framework for prosecutors, clarifying that corporate intent can be proven not only by direct orders from leadership but also by inference from a consistent pattern of criminal conduct within the business. This precedent makes it more difficult for corporations to evade responsibility by blaming 'rogue employees' for systemic wrongdoing.
