A. Receiving stolen property means intentionally to receive, retain or dispose of stolen property knowing that it has been stolen or believing it has been stolen, unless the property is received, retained or disposed of with intent to restore it to the owner.
B. The requisite knowledge or belief that property has been stolen is presumed in the case of a dealer who:
(1) is found in possession or control of property stolen from two or more persons on separate occasions;
(2) acquires stolen property for a consideration that the dealer knows is far below the property's reasonable value. A dealer shall be presumed to know the fair market value of the property in which the dealer deals; or
(3) is found in possession or control of five or more items of property stolen within one year prior to the time of the incident charged pursuant to this section.
C. For the purposes of this section:
(1) "dealer" means a person in the business of buying or selling goods or commercial merchandise; and
(2) "stolen property" means any property acquired by theft, larceny, fraud, embezzlement, robbery or armed robbery.
D. Whoever commits receiving stolen property when the value of the property is two hundred fifty dollars ($250) or less is guilty of a petty misdemeanor.
E. Whoever commits receiving stolen property when the value of the property is over two hundred fifty dollars ($250) but not more than five hundred dollars ($500) is guilty of a misdemeanor.
F. Whoever commits receiving stolen property when the value of the property is over five hundred dollars ($500) but not more than two thousand five hundred dollars ($2,500) is guilty of a fourth degree felony.
G. Whoever commits receiving stolen property when the value of the property is over two thousand five hundred dollars ($2,500) but not more than twenty thousand dollars ($20,000) is guilty of a third degree felony.
H. Whoever commits receiving stolen property when the value of the property exceeds twenty thousand dollars ($20,000) is guilty of a second degree felony.
I. Whoever commits receiving stolen property when the property is a firearm is guilty of a fourth degree felony when its value is less than two thousand five hundred dollars ($2,500).
History: 1953 Comp., § 40A-16-11, enacted by Laws 1963, ch. 303, § 16-11; 1969, ch. 171, § 2; 1972, ch. 77, § 1; 1975, ch. 232, § 1; 1983, ch. 253, § 1; 1987, ch. 121, § 5; 2006, ch. 29, § 7.
ANNOTATIONSCross references. — For failure to show proper authority, hides and pelts of cattle or sheep killed being evidence of larceny or receiving stolen property, see 77-17-14 NMSA 1978.
For evidentiary rule regarding presumptions in criminal cases, see Rule 11-302 NMRA.
The 2006 amendment, effective July 1, 2006, increased the value of the property in Subsection D from $100 or less to $250 or less; increased the value of the property in Subsection E from more than $100 but less than $250 to more than $250 but less than $500; increased the value of the property in Subsection F from more than $250 to more than $500.
The 1987 amendment, effective June 19, 1987, added present Subsections E and H, while redesignating former Subsections E, F and G as present Subsections F, G and I.
The 1983 amendment, effective June 17, 1983, in Subsection C, divided the formerly undivided language into an introductory paragraph and Paragraph (1), added "and" at the end of Paragraph (1) and added Paragraph (2).
I. IN GENERAL.
Unit of prosecution. — A defendant's possession of a stolen firearm is a separate offense from simultaneous possession of other stolen items. State v. Watkins, 2008-NMCA-060, 144 N.M. 66, 183 P.3d 951, cert. denied, 2008-NMCERT-003, 143 N.M. 681, 180 P.3d 1180.
The purpose of Subsection B was not to create a separate crime where several items of property, including a firearm or firearms, were stolen or received together with other stolen property, but was to increase the penalty for the offense where a firearm was the subject of the theft or receiving of stolen property regardless of the value of the firearm. State v. Smith, 1983-NMCA-077, 100 N.M. 352, 670 P.2d 963, overruled by State v. Watkins, 2008-NMCA-060, 144 N.M. 66, 183 P.3d 951.
Evidence that a defendant was in possession of numerous items of recently stolen personal property, wrongfully taken from different owners at different times, gives rise to a reasonable inference that defendant knew the property was stolen. State v. Smith, 1983-NMCA-077, 100 N.M. 352, 670 P.2d 963, overruled by State v. Watkins, 2008-NMCA-060, 144 N.M. 66, 183 P.3d 951.
Validity. — Even if Subsection B renders this section partially invalid, as trial court had held, Subsection A is valid absent Subsection B. State v. Elam, 1974-NMCA-075, 86 N.M. 595, 526 P.2d 189, cert. denied, 86 N.M. 593, 526 P.2d 187.
Section inapplicable to embezzled property. — In the absence of a statutory provision which expressly declares the offense of embezzlement to be embraced within the offense of larceny, the crime of receiving stolen property, knowing it to have been stolen, does not include property which was embezzled. State v. Bryant, 1982-NMCA-178, 99 N.M. 149, 655 P.2d 161 (decided under prior law).
II. MULTIPLE PROSECUTIONS.
Multiple charges. — Even where only one building is burglarized, multiple burglary charges are proper when the security interests of multiple victims are involved. State v. Soto, 2001-NMCA-098, 131 N.M. 299, 35 P.3d 304, cert. denied, 131 N.M. 64, 33 P.3d 284.
Receiving not included in armed robbery. — Offense of receiving stolen property cannot be included within the offense of armed robbery. State v. Mares, 1968-NMCA-042, 79 N.M. 327, 442 P.2d 817.
Prosecution for armed robbery not barred. — Plaintiff who was convicted in a justice of the peace court (now replaced by magistrate courts) of the petty misdemeanor of receiving stolen property, and was later convicted in the district court of the second degree felony of armed robbery, was not placed in double jeopardy, nor was the state barred or estopped from prosecuting and convicting him for the armed robbery. State v. Gleason, 1969-NMCA-054, 80 N.M. 382, 456 P.2d 215.
Conviction for receiving as bar to burglary prosecution. — New Mexico cannot convict a person under one indictment or information of receiving stolen property, and then subsequently convict him under another indictment or information of burglary, if the burglary conviction is dependent upon a theft by him of the same property, and he is shown to have been the person who actually took and asported the property during the burglarious entry. State v. Gleason, 1969-NMCA-054, 80 N.M. 382, 456 P.2d 215.
Theft inconsistent with receiving. — The felonious receiving of stolen property, knowing the same to have been stolen, was a substantive offense, and distinct from larceny. Where evidence showed defendant guilty of the theft, he could not be convicted of feloniously receiving it. Territory v. Graves, 1912-NMSC-027, 17 N.M. 241, 125 P. 604.
Disposition separate from larceny. — A thief who holds on to stolen property cannot violate this section by receiving the stolen property because he cannot receive it from himself, nor can the thief violate the statute by retaining the stolen property because larceny is a continuing offense; the thief's disposition, however, is action separate from the larceny, and it is neither absurd nor unreasonable to hold that the thief violates this section when he disposes of the property that he stole. State v. Tapia, 1976-NMCA-042, 89 N.M. 221, 549 P.2d 636, cert. denied, 89 N.M. 206, 549 P.2d 284.
Principle that one who is a thief cannot be convicted of "receiving" property he stole since the theft and receipt are the same act was inapplicable where defendant was convicted of "disposing of" property which he may also have stolen although he was acquitted of the theft. State v. Mitchell, 1974-NMCA-057, 86 N.M. 343, 524 P.2d 206.
Meaning of "disposing" shown by legislative history. — Since the legislature is presumed to have known the law when it added the "disposing" provision by the 1972 amendment, and is presumed to have intended to change it, so that, even if prior law prohibited conviction for both theft and disposing of the same property the legislative history supports the view that the law has been changed. State v. Tapia, 1976-NMCA-042, 89 N.M. 221, 549 P.2d 636, cert. denied, 89 N.M. 206, 549 P.2d 284.
Simultaneous possession of stolen items owned by different individuals is a single act constituting one offense. Sanchez v. State, 1982-NMSC-012, 97 N.M. 445, 640 P.2d 1325.
Property taken from more than one owner or at more than one time cannot be combined together into one count, thereby combining the values of the stolen items to increase the penalty. Sanchez v. State, 1982-NMSC-012, 97 N.M. 445, 640 P.2d 1325.
The defendant may be charged with a separate count for each separate transaction of disposal. Sanchez v. State, 1982-NMSC-012, 97 N.M. 445, 640 P.2d 1325.
Conviction for receipt back of property stolen. — If a thief steals property, turns that property over to someone and subsequently receives the property back from that person, a receiving conviction based on receipt of the stolen property by the thief would not be prohibited. State v. Tapia, 1976-NMCA-042, 89 N.M. 221, 549 P.2d 636, cert. denied, 89 N.M. 206, 549 P.2d 284.
Each separate "receiving" is a separate crime. State v. Bell, 1977-NMCA-014, 90 N.M. 160, 560 P.2d 951, cert. denied, 90 N.M. 254, 561 P.2d 1347.
If defendant received the stolen pistol at a time different from the time that he received the other stolen properties, then there were two offenses for which two sentences would be imposed even though at the time of discovery defendant possessed all the stolen property involved. State v. Bell, 1977-NMCA-014, 90 N.M. 160, 560 P.2d 951, cert. denied, 90 N.M. 254, 561 P.2d 1347.
Dual prosecutions alleging different ownership of same property. — A former acquittal under an indictment for buying and receiving stolen property, charged to be the property of A, was no bar to a prosecution for buying and receiving the same property charged to be the property of B. This was true where difference in name of owner of property was "railroad" and "railway." State v. Jacoby, 1919-NMSC-012, 25 N.M. 224, 180 P. 462.
III. ELEMENTS OF OFFENSE.
Purpose. — An obvious purpose of this section was to inhibit the movement and disposition of stolen property, and the holding that the section applies to a thief who disposes of stolen property is consistent with that purpose. State v. Tapia, 1976-NMCA-042, 89 N.M. 221, 549 P.2d 636, cert. denied, 89 N.M. 206, 549 P.2d 284.
Meaning of "dispose". — The ordinary meaning of the language "dispose of stolen property" is to transfer, relinquish or get rid of stolen property, which language does not show an intent to exclude the thief from the prohibition against disposing of stolen property. State v. Tapia, 1976-NMCA-042, 89 N.M. 221, 549 P.2d 636, cert. denied, 89 N.M. 206, 549 P.2d 284.
The ordinary meaning of "dispose" is "to transfer, relinquish or get rid of;" thus, when the defendant gave stolen money to friends, he transferred it to them. State v. Hernandez, 2003-NMCA-131, 134 N.M. 510, 79 P.3d 1118, cert. denied, 2003-NMCERT-002, 134 N.M. 723, 82 P.3d 533.
Money is "property". The legislature intended that "property" include "anything of value;" common sense supports the conclusion that "anything of value" includes money. State v. Hernandez, 2003-NMCA-131, 134 N.M. 510, 79 P.3d 1118, cert. denied, 2003-NMCERT-002, 134 N.M. 723, 82 P.3d 533.
Several methods of committing offense. — Prior to 1972 amendment, this section provided four methods by which offense could be committed, namely, buying, procuring, receiving or concealing stolen property; proof of any one of these methods, coupled with requisite knowledge, was sufficient to sustain a conviction. State v. Carlton, 1971-NMCA-019, 82 N.M. 537, 484 P.2d 757, cert. denied, 82 N.M. 534, 484 P.2d 754.
This section contemplates that a person may commit "receiving stolen property" in one of three ways. The property may be "received," or the property may be "retained," or the property may be "disposed" of by a defendant. Proof of any one of these methods, coupled with the requisite knowledge, is sufficient to sustain a conviction. Sanchez v. State, 1982-NMSC-012, 97 N.M. 445, 640 P.2d 1325.
Actual theft and knowledge thereof required. — To establish the crime of receiving and concealing stolen property it is incumbent upon the state to prove that the property in this case was stolen; and that the accused received the property with knowledge that they were stolen. State v. Zarafonetis, 1970-NMCA-064, 81 N.M. 674, 472 P.2d 388, cert. denied, 81 N.M. 669, 472 P.2d 383.
Knowledge required. — To constitute the crime of receiving stolen goods, it was essential that accused have knowledge that goods were stolen. State v. Floyd, 1918-NMSC-057, 24 N.M. 31, 172 P. 188.
Lost property not "stolen property". — Defendant could not be charged with receiving stolen property based on his possession of a lost traveler's check. State v. Carbajal, 2001-NMCA-015, 130 N.M. 284, 24 P.3d 316, rev'd on other grounds, 2002-NMSC-019, 132 N.M. 326, 48 P.3d 64.
Specific intent is not essential element of the crime of receiving stolen property. State v. Viscarra, 1972-NMCA-125, 84 N.M. 217, 501 P.2d 261.
"Dishonest intent" is not essential element. — "Dishonest intent" is not an element of the statutory crime of receiving stolen property. State v. Viscarra, 1972-NMCA-125, 84 N.M. 217, 501 P.2d 261.
Nature of presumption herein. — Rule 303(c), N.M.R. Evid. (now Rule 11-302 NMRA), abolishes "true" presumptions in criminal cases and puts the presumptions found in Subsection B of this section into the category of permissible inference, so that that subsection must be read to say that requisite knowledge or belief that property has been stolen may be, rather than is, presumed to exist upon proof of the basic facts. State v. Jones, 1975-NMCA-078, 88 N.M. 110, 537 P.2d 1006, cert. denied, 88 N.M. 318, 540 P.2d 248.
IV. EVIDENCE.
Possession not inferred solely from access. — When persons other than the defendant had equal or greater access to the place where the illicit goods were discovered, possession may not be inferred solely from defendant's access. Something more is necessary to establish a link between the items and the defendant before the jury can properly infer that defendant could control the items. State v. Sizemore, 1993-NMCA-079, 115 N.M. 753, 858 P.2d 420, cert. denied, 115 N.M. 709, 858 P.2d 85.
Circumstantial evidence of guilty knowledge. — Guilty knowledge is rarely susceptible of direct and positive proof and generally can be established only through circumstantial evidence. State v. Zarafonetis, 1970-NMCA-064, 81 N.M. 674, 472 P.2d 388, cert. denied, 81 N.M. 669, 472 P.2d 383.
Unless a defendant admits knowledge of the fact that goods he has received are stolen, this knowledge, of necessity, must be established by circumstantial evidence. State v. Lindsey, 1969-NMCA-121, 81 N.M. 173, 464 P.2d 903, cert. denied, 81 N.M. 140, 464 P.2d 559, and cert. denied, 398 U.S. 904, 90 S. Ct. 1692, 26 L. Ed. 2d 62 (1970).
Exclusion of reasonable hypotheses of innocence. — Where circumstantial evidence alone is relied upon for a conviction such evidence must be incompatible with the innocence of the accused upon any rational theory and incapable of explanation upon any reasonable hypothesis of the defendant's innocence. State v. Zarafonetis, 1970-NMCA-064, 81 N.M. 674, 472 P.2d 388, cert. denied, 81 N.M. 669, 472 P.2d 383.
Mere presence insufficient. — Although defendant was present in the house where the stolen bits were found, his presence alone is insufficient evidence on which to base a conviction. State v. Browder, 1971-NMCA-150, 83 N.M. 238, 490 P.2d 680.
Mere possession insufficient. — Mere possession of recently stolen property is not sufficient to warrant conviction on a charge of receiving stolen property, but possession, if not satisfactorily explained, is a circumstance to be taken into consideration with all of the other facts and circumstances in the case in determining guilt or innocence. State v. Follis, 1960-NMSC-074, 67 N.M. 222, 354 P.2d 521; State v. Olloway, 1980-NMCA-119, 95 N.M. 167, 619 P.2d 843.
Inference of possession or knowlege. — Although knowledge that the property is stolen may be circumstantially proved by unexplained possession, knowledge should not be inferred from possession or possession from knowledge without having some basis in fact for the initial inference. State v. Sizemore, 1993-NMCA-079, 115 N.M. 753, 858 P.2d 420, cert. denied, 115 N.M. 709, 858 P.2d 85.
Possession of stolen property is circumstance to be considered in determining whether the offense has been committed. State v. Elam, 1974-NMCA-075, 86 N.M. 595, 526 P.2d 189, cert. denied, 86 N.M. 593, 526 P.2d 187.
False explanation of possession. — Any false explanation of possession of stolen property is a circumstance indicative of guilt. State v. Elam, 1974-NMCA-075, 86 N.M. 595, 526 P.2d 189, cert. denied, 86 N.M. 593, 526 P.2d 187.
Manner of purchase and sale. — Evidence that defendant had the stolen goods in his possession within a few days after the theft, and both purchased and sold them at prices disproportionately low in comparison with their value, directing that the check in payment of the goods be written so as to exclude his name from the transaction, met the test of substantiality and justified the inference that the goods were received by defendant with knowledge that they were stolen. State v. Zarafonetis, 1970-NMCA-064, 81 N.M. 674, 472 P.2d 388, cert. denied, 81 N.M. 669, 472 P.2d 383.
Concealment and falsifying. — Evidence that defendant used different names in operating his business, that he used an embosser to obliterate the seals on the stolen books and that he told different stories about his acquisition of the stolen property was sufficient, even apart from evidence of possession, to sustain a conviction under this section. State v. Elam, 1974-NMCA-075, 86 N.M. 595, 526 P.2d 189, cert. denied, 86 N.M. 593, 526 P.2d 187.
Evidence of value. — The victim's testimony of the value of the stolen items, together with photographic and physical exhibits of the items was sufficient to allow the jury to conclude that the market value of the items possessed by defendant exceeded $500. State v. Archuleta, 2012-NMCA-007, 269 P.3d 924, cert. denied, 2011-NMCERT-012.
Motel manager's testimony that he was familiar with the value of the television sets that are sold to motels and testified that a used set like the one involved was worth between $150 and $200 was competent and meets the substantial evidence test. State v. Williams, 1972-NMCA-011, 83 N.M. 477, 493 P.2d 962.
Facsimile of bill of sale. — Introduction of a photocopy of a bill of sale for an electric typewriter sold by defendant to a witness, the original of which was claimed to have been lost, was not error, despite fact that counsel for defendant speculated the original might have been signed "(owner's name) by (defendant)." State v. Chacon, 1969-NMCA-112, 80 N.M. 799, 461 P.2d 932.
Credibility and weight of evidence for jury. — The jury was not required to accept a suggested source of acquisition of television set, disregarding all the evidence which supported a finding that defendant knew the set was stolen, since it was for the jury to weigh the evidence and pass on the credibility of the witness. State v. Lindsey, 1969-NMCA-121, 81 N.M. 173, 464 P.2d 903, cert. denied, 81 N.M. 140, 464 P.2d 559, and cert. denied, 398 U.S. 904, 90 S. Ct. 1692, 26 L. Ed. 2d 62 (1970).
Review of evidence on appeal. — In considering the question whether defendant knew property was stolen, the court will view the evidence in the light most favorable to the state, resolving all conflicts therein and indulging all permissible inferences in favor of the verdict of conviction of receiving and concealing stolen goods. State v. Zarafonetis, 1970-NMCA-064, 81 N.M. 674, 472 P.2d 388, cert. denied, 81 N.M. 669, 472 P.2d 383.
V. PROCEDURE.
Venue proper. — Venue was properly laid in county where concealment of stolen riding equipment occurred. State v. Carlton, 1971-NMCA-019, 82 N.M. 537, 484 P.2d 757, cert. denied, 82 N.M. 534, 484 P.2d 754.
Allegation of ownership was essential in indictment for buying and receiving stolen property, and a departure in the proof from the allegation in the indictment was necessarily fatal to the proceedings. State v. Jacoby, 1919-NMSC-012, 25 N.M. 224, 180 P. 462.
Allegation of source unnecessary. — It was not necessary that indictment set out from whom the stolen goods were received. Territory v. Claypool, 1903-NMSC-002, 11 N.M. 568, 71 P. 463.
Charging in alternative. — An indictment which charged buying, receiving or concealing in the alternative, through the use of the word "or," was established by proof of any one of them, although they were charged in a single count. Territory v. Neatherlin, 1906-NMSC-023, 13 N.M. 491, 85 P. 1044.
Indictment adequate. — Where the indictment charged defendant with receiving and concealing stolen property contrary to statutory provisions, further alleging that: "On diverse dates between March 20, 1965, and the 19th day of March, 1968 . . . [the defendant] did buy, procure, receive, or conceal things of value knowing the same to have been stolen or acquired by fraud or embezzlement" the indictment was in substantially the form prescribed by statute, and, insofar as form is concerned, no greater degree of conformity was required. State v. Lindsey, 1969-NMCA-121, 81 N.M. 173, 464 P.2d 903, cert. denied, 81 N.M. 140, 464 P.2d 559, and cert. denied, 398 U.S. 904, 90 S. Ct. 1692, 26 L. Ed. 2d 62 (1970).
Unclear indictment to be dismissed. — Where the defendant cannot tell whether he is being charged with "receiving," "retaining" or "disposing" of stolen property, nor can it be determined whether the charges are being "stacked" to enhance the penalty, the indictment is faulty and must be dismissed. Sanchez v. State, 1982-NMSC-012, 97 N.M. 445, 640 P.2d 1325.
Effect of variance. — In prosecution for receiving and concealing stolen property, alleged variance between all the evidence and the indictment was not ground for acquittal, as court could at any time cause the indictment to be amended, nor did defense counsel's failure to object thereto establish his ineffectiveness. State v. Chacon, 1969-NMCA-112, 80 N.M. 799, 461 P.2d 932.
Use of conjunctive rather than disjunctive. — Where, through error, the information and the court's instructions defined the offense of buying, receiving or aiding in the concealment of stolen property conjunctively rather than disjunctively as in the statute, the defendant was not aided thereby since there was substantial evidence to show that he was guilty of all three offenses. State v. Russell, 1933-NMSC-018, 37 N.M. 131, 19 P.2d 742.
Instruction regarding type of intent. — Where on appeal it was contended an error occurred for the district court to give a general intent instruction without instructing the jury that it did not apply to a specific intent crime, because the instruction substantially followed the applicable law, there was no fundamental error. State v. Gee, 2004-NMCA-042, 135 N.M. 408, 89 P.3d 80, cert. denied, 2004-NMCERT-003, 135 N.M. 261, 88 P.3d 261.
Intent-to-return defense. — For the intent-to-return defense to apply, the stolen goods should never have been held for any purpose other than to return the goods to the owner. State v. Lopez, 1990-NMCA-016, 109 N.M. 578, 787 P.2d 1261.
The prospect of a reward does not defeat the intent-to-return defense. State v. Lopez, 1990-NMCA-016, 109 N.M. 578, 787 P.2d 1261.
The Uniform Jury Instructions do not preclude an instruction on the intent-to-return defense when appropriate. State v. Lopez, 1990-NMCA-016, 109 N.M. 578, 787 P.2d 1261.
Defendant was entitled to an instruction on the intent-to-return defense, where reasonable doubt could arise from the possibility that defendant's involvement consisted of only awareness of the burglary, knowledge of where the goods were being kept, use of reward money from an investigator to purchase the goods from those holding them, and delivery of the goods to the investigator. State v. Lopez, 1990-NMCA-016, 109 N.M. 578, 787 P.2d 1261.
Waiver of error in instruction. — Error committed by trial court in instructing the jury that requisite knowledge must, rather than may, be presumed upon proof of basic facts, which was not objected to, was waived and did not constitute fundamental error. State v. Jones, 1975-NMCA-078, 88 N.M. 110, 537 P.2d 1006, cert. denied, 88 N.M. 318, 540 P.2d 248.
Law reviews. — For article, "The Confusing Law of Criminal Intent in New Mexico," see 5 N.M.L. Rev. 63 (1974).
For annual survey of New Mexico law relating to criminal law, see 12 N.M.L. Rev. 229 (1982).
For annual survey of New Mexico law relating to criminal law, see 13 N.M.L. Rev. 323 (1983).
Am. Jur. 2d, A.L.R. and C.J.S. references. — 66 Am. Jur. 2d Receiving and Transporting Stolen Property §§ 1 to 4.
Possession of recently stolen goods by one charged with receiving them as evidence on question of guilty knowledge, 68 A.L.R. 187.
Thief as accomplice of one charged with receiving stolen property, or vice versa, within rule requiring corroboration or cautionary instruction, 53 A.L.R.2d 817.
Receiving property stolen in another state or country as receiving stolen property, 67 A.L.R.2d 752.
Attempts to receive stolen property, 85 A.L.R.2d 259.
Indictment: sufficiency of description of stolen property in indictment or information for receiving it, 99 A.L.R.2d 813.
Public documents: receipt of public documents taken by another as receipt of stolen property, 57 A.L.R.3d 1211.
Accomplice: receiver of stolen goods as accomplice of thief for purposes of corroboration, 74 A.L.R.3d 560.
What constitutes "recently" stolen property within rule inferring guilt from unexplained possession of such property, 89 A.L.R.3d 1202.
What constitutes "constructive" possession of stolen property to establish requisite element of possession supporting offense of receiving stolen property, 30 A.L.R.4th 488.
Conviction of receiving stolen property, or related offenses, where stolen property previously placed under police control, 72 A.L.R.4th 838.
Possession of stolen property as continuing offense, 24 A.L.R.5th 132.
Participation in larceny or theft as precluding conviction for receiving or concealing the stolen property, 29 A.L.R.5th 59.
76 C.J.S. Receiving Stolen Goods § 1 et seq.