People v. Williams, 62 N.Y.2d 765 (1984)
When the circumstances indicate the defendant was either guilty of stealing the property or not guilty at all, a charge on recent and exclusive possession is appropriate, and there is no need to charge the jury on the separate crime of possession of stolen property.
Summary
The New York Court of Appeals affirmed the Appellate Division’s order, holding that the trial court’s charge on recent and exclusive possession was not erroneous because the evidence presented at trial indicated the defendant was either guilty of stealing from the complainant or not guilty at all. The Court distinguished this case from cases where a reasonable view of the evidence could support a conviction for possession of stolen property without also finding the defendant guilty of the theft itself. Furthermore, the court found the identification evidence sufficient to present a jury question and determined that the defendant’s statement at the time of arrest was spontaneous and admissible.
Facts
The complainant was robbed, and during a chase, the officers and complainant briefly lost sight of the defendant. The complainant identified the person being chased to the police as the robber, and the officer identified the apprehended person as the person pointed out to him. The defendant was found to be in possession of the complainant’s property. At the time of the arrest, the defendant made a statement that the court later deemed spontaneous.
Procedural History
The defendant was convicted at trial. The Appellate Division affirmed the conviction. The case was then appealed to the New York Court of Appeals.
Issue(s)
1. Whether the trial court erred in its charge to the jury regarding recent and exclusive possession of stolen property.
2. Whether the evidence presented at trial was sufficient to establish identification of the defendant as the perpetrator.
3. Whether the statement made by the defendant at the time of arrest was admissible.
Holding
1. No, because the circumstances of the case indicated that the defendant was either guilty of stealing from the complainant or guilty of nothing, making a separate charge on possession of stolen property unnecessary.
2. Yes, because the complainant pointed out the person being chased to the police as the robber, and the officer identified the apprehended person as the person pointed out to him, and that together with the defendant’s possession of complainant’s property was sufficient to present a jury issue on identification.
3. Yes, because the statement was spontaneous, resulting from the officer’s response to the defendant’s question, and that response was a simple statement of fact, not provocative in any sense.
Court’s Reasoning
The Court reasoned that the charge on recent and exclusive possession was not error because the evidence suggested the defendant was either guilty of stealing or not guilty at all. The Court distinguished the case from People v. Baskerville, where there was a reasonable view of the evidence under which the defendant could be guilty of possession of stolen property without being guilty of the theft itself. Here, no such view existed. Regarding identification, the Court found the complainant’s identification of the defendant during the chase, coupled with the defendant’s possession of the stolen property, sufficient to present a jury question. Finally, the Court determined that the defendant’s statement at the time of arrest was spontaneous and admissible because it resulted from the officer’s non-provocative response to the defendant’s question. The court stated that the officer’s response was simply “a simple statement of fact, not provocative in any sense.” The Court found no merit in the defendant’s remaining contentions, affirming the Appellate Division’s order.