State v. Beale

Brief Fact Summary. Appellant was informed that items for sale in his antique shop were possibly stolen and to put them aside for further investigation. Appellant was convicted of knowingly concealing stolen property after he sold the items in question.

Synopsis of Rule of Law. The State of Maine must prove that Appellant himself had actual knowledge that the goods were stolen.

Facts. Appellant owned an antique shop. On the date in question, his wife operated the shop. Mrs. Johnson entered the shop and noticed items that appeared to have been stolen from her several months earlier. Mrs. Johnson returned to the shop later that day with a police officer who instructed Appellant’s Wife to have Appellant contact him. When the police again contacted Appellant, he told them he has sold several of the items, despite the instructions of the police to put them aside. Appellant was convicted of knowingly concealing stolen property.

Issue. Whether the standard of knowledge for this crime is subjective or objective.

Held. Appeal granted, and case is remanded.
The true test is subjective and is whether Appellant himself knew that the goods were stolen. The test is not objective.

The defendant does not have to have direct knowledge or positive proof that the goods were stolen; it is enough if he was made aware of circumstances which caused him to believe that they were stolen.

Discussion. The Court explained that there existed a majority view which adopted a subjective test of knowledge, and a minority view that an objective standard should be used. The Court in this case opts for the majority view. In their opinion, the ‘reasonable person’ objective standard is not fit for criminal prosecutions. The very essence of a crime is intentional wrongdoing, thus the subjective standard is more appropriate because it focuses on the mental state of the specific defendant.