State v. Beale

Rule of Law:

A conviction for knowingly receiving or concealing stolen property requires proof of the defendant's actual, subjective belief that the property was stolen; it is not sufficient to prove merely that a reasonable person in the defendant's position would have had such a belief.

Facts:

• Mrs. Johnson identified several items in Mr. Beale's antique shop as property that had been stolen from her months earlier.
• Mrs. Johnson returned with a police officer, who told Mr. Beale's wife, Mrs. Beale, that the items were "possibly stolen" and should be set aside and not sold.
• Mrs. Beale placed the identified items on a shelf as requested.
• Mrs. Beale informed her husband, the defendant Mr. Beale, that Mrs. Johnson claimed the items were stolen and that the officer had asked for them to be put aside.
• The next day, Mr. Beale put the items back in his display counter for sale.
• Mr. Beale then sold many of the items, including those with the distinctive initials Mrs. Johnson had used for identification.
• When questioned by a deputy sheriff, Mr. Beale admitted he sold the items despite the officer's request, stating he believed he had valid receipts and lawful possession of them.

Procedural Posture:

• The Defendant, Mr. Beale, was charged in a trial court with the offense of knowingly concealing stolen property.
• At the conclusion of his trial, the Defendant's counsel requested a specific jury instruction regarding the defendant's subjective belief, which the court denied.
• The trial judge instructed the jury that the knowledge requirement could be met if a 'reasonably prudent man' would have believed the goods were stolen.
• Defendant's counsel objected to the jury instruction, arguing the correct test was the defendant's actual knowledge.
• The jury returned a verdict of guilty.
• The Defendant appealed his conviction to the Supreme Judicial Court of Maine.