McFarlane v. State

Summary

The Wyoming Supreme Court reviewed James Charles McFarlane’s conviction for larceny and considered whether the evidence was sufficient to prove that he stole a snowmobile rather than merely possessed stolen property. The court held that the recency of McFarlane’s possession, along with other circumstantial evidence, supported a reasonable inference that he had taken the snowmobile. The judgment and sentence were affirmed.

Holdings

1. The evidence was sufficient for a reasonable jury to find beyond a reasonable doubt that McFarlane stole, took, and carried away the snowmobile with intent to deprive its owner or lawful possessor.
2. The recency requirement for inferring theft from unexplained possession of recently stolen property was satisfied because McFarlane possessed the snowmobile within days of its last known possession, and the circumstances remained sufficiently recent even if measured from the latest possible theft date.

Questions Presented

1. Whether the evidence was sufficient to sustain McFarlane's conviction for larceny.
2. Whether possession of the snowmobile within a short period after its disappearance, together with the surrounding circumstances, permitted the jury to infer that McFarlane obtained it by taking rather than merely receiving or possessing stolen property.

Disposition

affirmed