State v. Sanders
1993 WL 276820, 622 So. 2d 817, 1993 La. App. LEXIS 2641 (1993)
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Rule of Law:
Knowledge that property is stolen, a required element for illegal possession of stolen things, may be proven through circumstantial evidence, particularly when the defendant is found in possession of a vehicle exhibiting obvious signs of theft, such as a broken steering column and damaged locks.
Facts:
- On October 10, 1987, James Richard Thomas parked his 1985 Cutlass Supreme in the French Quarter of New Orleans.
- Two hours later, Thomas returned to find his car missing and subsequently reported it stolen to the police.
- Around 2:30 A.M. on October 11, 1987, Ronald Sanders accepted a ride from a man he met at a bar; the man then drove to Lowerline, stopped, went upstairs, and never returned.
- Sanders remained in Thomas's car with the motor running from 2:30 A.M. until 7 A.M., pulling it over to the curb, and during this time, he put on a blue fraternity jacket given to him by the man.
- The 1985 Cutlass Supreme had a broken steering column, one broken door lock, a ripped-off trunk lock, and a dented back; a screwdriver was found between the front seats of the car.
- At approximately 7 A.M. on October 11, 1987, NOPD Officer Cornell Day found Ronald Sanders asleep in the driver's seat of the car at Fern and Olive Streets, with the engine running and the car blocking the corner.
- Upon identification, Thomas confirmed the car was his, noted the extensive damage, and recognized his fraternity jacket on Sanders, which had been in the trunk. Thomas had not given anyone permission to drive his car.
Procedural Posture:
- On December 4, 1987, Ronald J. Sanders was charged by bill of information with possession of stolen property in violation of LSA-R.S. 14:69.
- At his arraignment on January 7, 1988, Sanders pleaded not guilty.
- Sanders elected a bench trial before the trial court.
- On February 22, 1988, the trial court found Sanders guilty as charged.
- On June 3, 1988, Sanders was sentenced as a second offender under R.S. 15:529.1 to serve five years at hard labor.
- On August 21, 1992, the Louisiana Court of Appeal, Fourth Circuit, granted Sanders' motion for an out-of-time appeal.
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Issue:
Does sufficient evidence exist to prove that Ronald Sanders knew or should have known a vehicle was stolen, thereby supporting a conviction for illegal possession of stolen things, when he was found asleep in a car with a broken steering column, damaged locks, and a screwdriver nearby, despite his claim of being given a ride by a stranger?
Opinions:
Majority - Plotkin, Judge
Yes, sufficient evidence exists to prove that Ronald Sanders knew or should have known the vehicle was stolen, thereby supporting his conviction for illegal possession of stolen things. The court applied the Jackson v. Virginia standard, viewing the evidence in the light most favorable to the prosecution, and found that a rational trier of fact could have found proof beyond a reasonable doubt of each essential element of the crime, including knowledge. The extensive visible damage to the car—a broken steering column, broken door lock, ripped-off trunk lock, and the presence of a screwdriver—constituted strong circumstantial evidence from which knowledge could be inferred, particularly given Sanders’ improbable explanation of being left in such a vehicle by an unknown person for several hours. The court noted that Louisiana R.S. 15:438, which requires that every reasonable hypothesis of innocence be excluded for circumstantial evidence, was met because Sanders’ testimony denying knowledge of the damage was not credible in light of the obvious defects. The court also cited State v. Wilson, where similar car damage was deemed sufficient to demonstrate a defendant's knowledge.
Analysis:
This case reinforces that the element of knowledge in illegal possession of stolen property can be established solely through strong circumstantial evidence, particularly when the physical condition of the property clearly indicates theft. It highlights the application of the Jackson v. Virginia standard and the Louisiana statutory requirement to exclude every reasonable hypothesis of innocence, demonstrating how a court evaluates the credibility of a defendant's explanation against objective physical evidence. The decision sets a precedent that obvious signs of vehicle tampering can be sufficient to overcome a claim of ignorance, thus making it more difficult for individuals to avoid conviction by claiming they were unaware of a vehicle's stolen status when visual evidence suggests otherwise.
