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Carter v. State

Citations: 231 Md. 409; 190 A.2d 548; 1963 Md. LEXIS 455Docket: No. 283

Court: Court of Appeals of Maryland; May 7, 1963; Maryland; State Supreme Court

Narrative Opinion Summary

In this case, the appellant was convicted of receiving stolen property and subsequently appealed the conviction, claiming insufficient evidence for the crime. The case hinged on whether the appellant knowingly received stolen goods with dishonest intent, a requirement for establishing the offense. The prosecution presented evidence that the appellant was present near the scene of the burglary, where his associate committed the theft and later handed over stolen shirts to him. The appellant was apprehended shortly after, in possession of the shirts. He contended that he was unaware of their stolen nature, having been assured by the associate that they were not stolen. The trial court dismissed this explanation as implausible, leading to a conviction. On appeal, the court affirmed the judgment, finding that the trial court's inference of guilt based on recent possession of stolen property was not clearly erroneous. The decision underscores the legal principle that possession of stolen goods shortly after a theft can substantiate an inference of guilt, especially when the defendant's account lacks credibility.

Legal Issues Addressed

Credibility of Defendant's Explanation

Application: The trial court assessed the credibility of the defendant's claim that he received the shirts innocently and found it implausible.

Reasoning: The trial court found his explanation implausible and determined he was guilty of receiving stolen property.

Elements of Receiving Stolen Property

Application: The court evaluated whether the defendant possessed the stolen property with knowledge of its stolen nature and dishonest intent.

Reasoning: To establish the crime, it must be shown that the defendant received stolen property with dishonest intent and knowledge of its stolen status.

Inference from Possession of Stolen Goods

Application: The court found the inference of guilt reasonable based on the fact that the defendant was apprehended with the stolen shirts shortly after the burglary.

Reasoning: The court's finding was not deemed clearly erroneous, as the inference of guilt from recent possession of stolen property is a factual matter.