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State Of Washington, V Matthew Glen Goins
75235-9
| Wash. Ct. App. | Oct 3, 2016
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Background

  • In November 2014 Tacoma officer found Matthew Goins with a motorcycle and a car on the street; the motorcycle was stolen. Goins was seen shielding the motorcycle's plate.
  • The motorcycle had a missing ignition lock and had to be started by holding wires together. Goins gave inconsistent accounts of how he acquired it (working on it, planned purchase, then that he already bought it for $1,000).
  • Officer recovered Dalton’s American Express card (also a Costco ID) from Goins’s wallet; that card had been stolen months earlier and the account had been canceled. Goins said he found the card in the street.
  • Goins was charged with possession of a stolen motor vehicle, possession of a controlled substance (not appealed), possession of stolen property/access device, and second-degree identity theft.
  • Jury convicted on all counts; on appeal the court reviews sufficiency of evidence as to knowing possession (motorcycle and card) and intent to commit a crime (identity theft).

Issues

Issue State's Argument Goins's Argument Held
Did the evidence support that Goins knew the motorcycle was stolen? Inferences from shielding the plate, inconsistent purchase stories, and broken ignition support guilty knowledge. Lack of direct proof; claimed purchase and bill of sale. Yes — jury could reasonably infer he knew it was stolen.
Did the evidence support that Goins knew the credit card was stolen? Possession in wallet plus implausible explanation (claimed he found it; no return means) is corroborating evidence of guilty knowledge. He found the card in the street and intended to return it; no use shown. Yes — slight corroboration sufficed to infer knowledge beyond reasonable doubt.
Did the evidence support that Goins intended to commit a crime using the card (identity theft)? Possession in wallet and card bearing a photo resembling Goins supports an inference of intent to impersonate/use it. Mere possession is insufficient to infer intent to commit a crime. No — possession alone (even with a similar photo) did not prove intent beyond a reasonable doubt; conviction reversed.
Remedy / disposition N/A N/A Affirm convictions for stolen vehicle and stolen property; reverse and dismiss identity theft; remand for resentencing.

Key Cases Cited

  • State v. Larson, 184 Wn.2d 843 (discusses State's burden to prove each element beyond a reasonable doubt)
  • State v. Salinas, 119 Wn.2d 192 (standard for sufficiency review: view evidence in light most favorable to the State)
  • State v. Vasquez, 178 Wn.2d 1 (possession alone is insufficient to infer intent to use contraband criminally)
  • State v. Hickman, 135 Wn.2d 97 (insufficient evidence requires reversal and dismissal)
  • State v. Couet, 71 Wn.2d 773 (recent possession alone not enough for conviction)
  • State v. Portee, 25 Wn.2d 246 (possession plus slight corroborative evidence may support an inference of guilty knowledge)
  • State v. Woods, 63 Wn. App. 588 (intent may be inferred from conduct and circumstances when logically probable)
Read the full case

Case Details

Case Name: State Of Washington, V Matthew Glen Goins
Court Name: Court of Appeals of Washington
Date Published: Oct 3, 2016
Docket Number: 75235-9
Court Abbreviation: Wash. Ct. App.