P. v. Garrett CA4/2
Savannah Marie Garrett appeals a jury verdict finding her guilty of driving a vehicle without consent of the owner and receiving a stolen vehicle. She argues we should reverse both convictions because insufficient evidence showed she drove or had possession of the car or knew it was stolen. She also argues the trial court erred by failing to instruct the jury they had to find she knew the car had been stolen to convict her of driving a vehicle without consent. Finally, she argues the trial court improperly reduced the burden of proof by directing the jury that, if it determined she was in possession of recently stolen property, it could infer guilt from additional corroborating evidence.
We conclude there was sufficient circumstantial evidence to establish Garrett possessed the stolen car, drove it, and knew it had been stolen, and the trial court instructed the jury properly. We therefore affirm the judgment.
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