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Criminal law — Sufficiency of the evidence — Theft of goods between $10,000 and $100,000

Following a three-day jury trial in September 2016 before the Circuit Court for Baltimore City, appellant Joseph Randall1 was convicted of theft of property valued $10,000 to $100,000 and sentenced to twelve years’ imprisonment. Appellant timely appealed and presents three questions for our review:

1. Is the evidence sufficient to support [a]ppellant’s conviction for theft of goods valued between $10,000 and $100,000, where the item stolen was a rental car and the State presented no evidence of the value of the car aside from its make and model and the lessee’s unfounded approximation as to value?

2. Did the trial court err when it admitted the lessee’s testimony regarding the approximate value of the vehicle, where the lessee was not qualified to give such testimony as either an expert or lay witness?

3. Did the trial court err in failing to provide a clarifying response to Jury Question No. 2 seeking clarification regarding whether “in Baltimore City” meant that the crime occurred in the city or the victims were from the city?

Read the opinion here: