CORE CRIMINAL LAW SUBJECTS: Crimes: Article 121 - Larceny and Wrongful Appropriation


2002

United States v. Whitten, 56 MJ 234 (the crime of larceny by taking continues as long as asportation of the property continues; factually, the original asportation continues as long as the perpetrator is not satisfied with the location of the goods and causes the flow of their movement to continue relatively uninterrupted).

(viewed under the standard for assessing legal sufficiency of the evidence, Court finds legally sufficient evidence to find appellant guilty of conspiracy to commit larceny and larceny where: (1) R and M formed an agreement, manifested by their conduct, to steal a duffel bag; (2) appellant joined the ongoing conspiracy to steal the duffel bag; (3) several overt acts in furtherance of the conspiracy were committed after appellant joined the conspiracy; and (4) appellant aided and abetted the larceny before asportation of the stolen property was complete).

2001

United States v. Binegar, 55 MJ 1 (an honest mistake of fact as to a soldier’s entitlement or authorization to take property is a defense to a charge of larceny under Article 121, UCMJ, one element of which is the specific intent to steal).

(a military superior’s permission to his subordinate to dispose of government property to other servicemembers is not the type of fact which is unrelated to a specific intent of the subordinate to steal from the Government; therefore, any mistake of fact must only be honest to provide a defense).

(military judge’s instructional error informing the members that appellant’s mistake must have been both honest and reasonable, rather than only honest in order to provide a defense to larceny was materially prejudicial where: (1) the instruction placed a lesser burden on the government to prove appellant’s guilt because it could secure his conviction by disproving either the honesty or the reasonableness of the mistake; (2) trial counsel exploited the erroneous instruction in his findings argument; and (3) the government presented a substantial case on the unreasonableness of appellant’s conduct, creating a reasonable possibility that the members resolved this case against appellant on this basis.

United States v. Pacheco, 56 MJ 1 (evidence was legally sufficient to show the wrongfulness of appellant’s taking or withholding of a weapon, as well as his intent permanently to deprive the owner of the use and benefit of the weapon, where that evidence revealed that appellant did not return the pistol or inform the authorities of its taking after being informed that the taking of weapons was not permitted and that all weapons had to be returned prior to a shakedown).

2000

United States v. Reed, 54 MJ 37 (viewing evidence as a whole, Court finds evidence of larceny and false official statements legally sufficient where the evidence showed that appellant stole a modem and then engaged in an elaborate cover-up after the modem was discovered to be missing).

1999

United States v. Russell, 50 MJ 99 (appellant’s guilty plea admission that stolen items were military property used by Air Force, even though items were never actually turned over to the government, provided sufficient basis in record to support guilty plea to larceny of military property).



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