People v. Smith, 79 N.Y.2d 309 (1992)
To convict a defendant of robbery, the prosecution must prove beyond a reasonable doubt that the defendant acted with the conscious objective of compelling the victim to deliver property or preventing resistance to the taking or retention of property; equivocal proof that allows the jury to impermissibly speculate as to the defendant’s mental state is insufficient.
Summary
The New York Court of Appeals reversed the Appellate Division’s order, holding that the evidence presented at trial was insufficient to establish that the defendant possessed the requisite mental culpability for robbery. The complainant, after being raped and sodomized by the defendant, offered her purse when the defendant threatened to kill her. The Court of Appeals found that the prosecution failed to prove beyond a reasonable doubt that the defendant threatened the complainant with the conscious objective of compelling her to deliver her property or preventing resistance. The dissent argued that the evidence allowed the jury to impermissibly speculate about the defendant’s intent.
Facts
After raping and sodomizing the complainant, the defendant informed her that he planned to kill her because she could identify him. The complainant pleaded for her life, offering her purse and money. The defendant then emptied her purse and fled with her money. He was apprehended and convicted of rape, sodomy, and robbery.
Procedural History
The defendant was convicted in the trial court of rape, sodomy, and robbery. The Appellate Division affirmed the robbery conviction. The New York Court of Appeals granted leave to appeal and reversed the Appellate Division’s order, vacating the robbery conviction.
Issue(s)
Whether the prosecution presented sufficient evidence at trial for the jury to rationally find that the defendant threatened the complainant with the conscious objective of compelling her to deliver up her property or preventing resistance to his taking or retention of that property, so as to sustain a robbery conviction.
Holding
No, because the evidence was too equivocal to establish beyond a reasonable doubt that the defendant acted with the mental culpability necessary to commit robbery.
Court’s Reasoning
The Court of Appeals found that the evidence did not sufficiently prove the defendant’s intent to commit robbery. The Court emphasized that the prosecution bears the burden of proving beyond a reasonable doubt that the defendant acted with the conscious objective of compelling the victim to deliver property or preventing resistance. The Court found the evidence presented at trial insufficient and stated that “the People’s proof in this regard, however, was highly equivocal…and could, in my view, only have left the jury to speculate impermissibly as to whether defendant acted with the requisite mental state.” The Court concluded that because the complainant offered her purse only after the defendant threatened to kill her for identifying him and not to prevent the sexual assault, the intent to rob was not clearly established.