Eres v. State

Summary

The Wyoming Supreme Court affirmed Fulgencio Eres's felony conviction for receiving stolen property valued at $1,000 or more. The court held that any error in instructing the jury on the timing of property valuation was harmless and concluded that sufficient evidence supported the property's market value.

Holdings

1. The court did not need to decide whether the statute required valuation at the time of theft or the time of receipt because the parties presented no evidence or argument that the property's value differed between those events. In any event, any instructional error was harmless beyond a reasonable doubt.
2. The evidence was sufficient for a reasonable jury to find beyond a reasonable doubt that the stolen property was worth $1,000 or more.

Questions Presented

1. Whether the district court erred by instructing the jury to determine the value of the stolen property at the time and place of the theft rather than at the time Eres received it.
2. Whether sufficient evidence supported the jury's finding that the stolen property had a value of at least $1,000.

Disposition

affirmed