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Name: People v. Williams
Case #: C097116
Opinion Date: 01/04/2024
Attorney: Robert L. Angres

On appeal, appellant argued there was insufficient evidence to support his convictions for vehicle theft and receipt of a stolen vehicle. Appellant was charged with vehicle theft and tried solely on the theory that he took the car without the owner’s consent. Neither party disputed appellant initially had consent from the rental car company to take the car, nor did either party dispute that appellant exceeded the scope of that consent when he failed to return the car as he had contracted to do. But exceeding the scope of the owner’s consent does not change the fact that the owner originally did consent to the taking. Because there is no evidence appellant took the car without the rental car company’s consent, there is insufficient evidence to support his conviction for vehicle theft. Because there was insufficient evidence the car was stolen, there necessarily was insufficient evidence to sustain appellant’s conviction for receiving stolen property.  The court reversed both of the challenged counts of conviction accordingly.