Com. v. Roane, S.
1492 EDA 2015
| Pa. Super. Ct. | Nov 21, 2016Background
- Steve (Kyle) Roane was convicted after a non-jury trial of four counts of receiving stolen property for arranging junk/tow sales of four vehicles and was sentenced to an aggregate 7–14 years plus $6,353 restitution.
- Between July and September 2013, four vehicles were taken from their owners without permission and subsequently sold to a tow/company (Hooked, Inc./Northside) as junk with towing agreements listing Roane as the seller/owner’s representative.
- Roane told police he acted as a mobile mechanic: in some instances he claimed he was asked by unidentified persons to junk the vehicles, received small payments ($0–$350), keys/registration for one vehicle, and completed tow paperwork without verifying owners’ identities or title.
- The trial court found Roane never possessed title, did not attempt to confirm ownership, and that the circumstances (low payments, immediate resale/junking, lack of inquiry) supported an inference he knew or should have known the cars were stolen.
- Roane appealed, arguing the Commonwealth failed to prove he knew the vehicles were stolen or believed they were probably stolen.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth proved Roane knew or believed the vehicles were stolen | Commonwealth: Circumstantial evidence (low payments, immediate resale, lack of inquiry, tow paperwork naming Roane) supports inference of knowledge | Roane: He acted as a mechanic; transactions were lawful repairs or gifts/payments for labor; he did not know vehicles were stolen | Court affirmed: Evidence sufficient — reasonable person would have known transaction was unlawful; conviction upheld |
Key Cases Cited
- Commonwealth v. Devries, 112 A.3d 663 (Pa. Super. 2015) (standard of review for sufficiency of the evidence)
- Commonwealth v. Parsons, 335 A.2d 800 (Pa. Super. 1975) (knowledge inferred from low price, lack of inquiry, and prompt resale)
- Commonwealth v. Nasuti, 123 A.2d 435 (Pa. 1956) (circumstantial evidence can establish guilt)
- Commonwealth v. Cohan, 111 A.2d 182 (Pa. Super. 1955) (disparity between value and price may support inference of stolen goods)
- Commonwealth v. Meyers, 34 A.2d 916 (Pa. Super. 1943) (Commonwealth need not show impossibility of innocence; must prove knowledge beyond reasonable doubt)