People v. Reyes

52 Cal. App. 4th 975, 61 Cal. Rptr. 2d 39 (1997)

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People v. Reyes

California Courts of Appeal
52 Cal. App. 4th 975, 61 Cal. Rptr. 2d 39 (1997)

Facts

A person matching the description of Ramiro Jaime Reyes (defendant) was seen reaching through the open window of a truck owned by Michael Conlon in the middle of the night. Reyes was later stopped for speeding. When the police searched the vehicle, they found property belonging to Conlon. Conlon confirmed that the property was stolen from his truck. Reyes claimed he had found the property on the side of the road while high and assumed it was garbage. Reyes was charged with vehicular burglary and receiving stolen property, but the burglary charge was dismissed because there was no evidence that the truck had been locked. At trial for the receiving-stolen-property charge, Reyes provided evidence of his long history of substance abuse and his intoxication on the night of the incident. Reyes also sought to introduce a psychologist’s testimony that his history of substance abuse and mental illness showed that he lacked the required element of knowledge that the property was stolen. However, under California law, evidence of a mental illness was admissible only to disprove a defendant’s specific intent. Because the crime of receiving stolen property was a general-intent crime, the trial court excluded the psychologist’s testimony about Reyes’s mental illness as irrelevant. Reyes was convicted and appealed.

Rule of Law

Issue

Holding and Reasoning (Huffman, J.)

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