Jayvon Williams v. United States, 155 A.3d 1286

Background

Appellant was charged with receiving stolen property (four identification cards), unlawful possession of ammunition (dismissed), and failure to obey a lawful order (acquitted). After a bench trial, he was convicted only of misdemeanor receiving stolen property; he appealed.
Evening before arrest, four men approached Officer Good to borrow his phone and gave their names. About 4:00 A.M. the next day, Officer Good saw a different group; he made eye contact with appellant, who nudged a backpack as if to move it out of view.
Appellant fled when officers approached; he was later found clutching the backpack. The backpack contained a bullet, a wallet, jewelry, watches, and four identification cards whose names/faces matched the men who had sought the officer’s phone earlier.
The identification cards were not introduced into evidence, and none had been reported stolen; Officer Good did not testify whether the cards were government-issued or valid.
At the station appellant said, referring to the other man, “He had nothing to do with it. You can let him go. I did it all on my own.” The trial judge relied on flight, concealment, contents of the backpack, the face/name matches, and that statement as circumstantial evidence of receiving stolen property.
The D.C. Court of Appeals reversed, holding the government failed to prove beyond a reasonable doubt that the cards were stolen or that appellant knew or had reason to believe they were stolen; remanded with directions to enter a judgment of acquittal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were the identification cards "stolen"?	The cards matched faces/names of men who earlier said they'd been robbed; inference of theft from timing and matching.	No direct proof of theft; cards not reported stolen; inference speculative.	No — insufficient evidence to infer a theft beyond a reasonable doubt.
Did appellant "know or have reason to believe" the cards were stolen?	Flight, concealment, clutching backpack, and admission at station show consciousness of guilt and knowledge.	Suspicious conduct does not prove knowledge that items were stolen; other innocent explanations possible.	No — circumstantial evidence did not establish knowledge beyond a reasonable doubt.
Did the trial judge impermissibly rely on hearsay (the officer’s reference to a robbery)?	Government relied on officer’s earlier contact and the inference of robbery.	Appellant argued the judge considered excluded hearsay about a robbery.	No — judge did not rely on the excluded hearsay itself but on permissible inferences from admitted facts.
Were the cards of "some value" (statutory element)?	Government asserted cards had value but did not produce proof.	Appellant challenged sufficiency on value as well.	Not addressed on the merits — court reversed based on insufficient proof the cards were stolen, so value issue left undecided.

Key Cases Cited

United States v. Harris, 435 F.2d 74 (D.C. Cir. 1970) (standard for sufficiency: evidence need only allow reasonable persons to find guilt beyond a reasonable doubt)
Roy v. United States, 652 A.2d 1098 (D.C. 1995) (fact-finder cannot resort to mere conjecture or speculation)
Nowlin v. United States, 782 A.2d 288 (D.C. 2001) (each element must be supported by inference, not speculation)
Robinson v. United States, 270 A.2d 144 (D.C. 1970) (circumstantial proof inadequate where it does not establish that an unlawful taking occurred)
In re D.D., 775 A.2d 1096 (D.C. 2001) (possession of recently stolen goods permits inference that possessor stole them, but requires proof property was stolen)
Head v. United States, 451 A.2d 615 (D.C. 1982) (discussing inferences from possession of recently stolen items)