Com. v. Ratliffe, R., Com. v. Ratliffe, R. No. 531 MDA 2016

Ratliffe was charged with receiving stolen property after police found Burkey Construction power tools in an apartment during a disturbance call.
Officer Sneeringer arrived early morning, encountered occupants, and discovered tool cases marked “Burkey” in a bedroom closet; Gonzalez consented to a search.
Burkey supervisor Concordia identified the recovered tools as those stolen from a nearby jobsite; the tools bore distinctive orange paint and company markings.
Police found Ratliffe’s driver’s license in a sweatshirt on a heater near the fire escape; Gonzalez testified Ratliffe was her boyfriend and father of her child.
Bergman testified Ratliffe lived with Gonzalez, told Bergman the tools were stolen, and asked Bergman to sell them; Ratliffe later tried to discourage Bergman from testifying.
A jury convicted Ratliffe; he appealed arguing insufficient evidence that he knew the tools were stolen.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence sufficed to prove Ratliffe knew or believed the tools were stolen	Commonwealth: circumstantial evidence (identifying marks, proximity to theft, Bergman’s testimony, Ratliffe’s license in apt.) allowed inference of knowledge	Ratliffe: mere possession and presence in apartment insufficient; no evidence of recency, modification, flight, or false explanations	Court affirmed: Bergman’s testimony that Ratliffe admitted the tools were stolen, plus distinctive markings and proximity to jobsite, permitted a jury inference of knowledge

Commonwealth v. Dale, 836 A.2d 150 (Pa. Super. 2003) (standard for reviewing sufficiency of the evidence)
Commonwealth v. Bruce, 916 A.2d 657 (Pa. Super. 2007) (circumstantial evidence may establish crimes)
Commonwealth v. Kinney, 863 A.2d 581 (Pa. Super. 2004) (appellate limits on credibility and weight determinations)
Commonwealth v. Robinson, 128 A.3d 261 (Pa. Super. 2015) (elements of receiving stolen property; definition of "knows")