How have courts dealt with allegations of fraudulent vehicle registration and forged certificate of title in criminal cases?

California, United States of America


The following excerpt is from People v. Eshaya, F066694 (Cal. App. 2014):

highway. (People v. Martinez, supra, at p. 1003.) The defendant had a suspended driver's license, and he produced an irregular registration card and a forged certificate of title for the vehicle. He told investigating officers he had been heading to Guatemala, and he did not know the car was stolen when he bought it. (Ibid.) He was charged with receiving stolen goods and other offenses. (Id. at p. 1002.) At his trial, two experts on auto theft rings testified many stolen vehicles of the same type were driven from California to Guatemala along the highway upon which the defendant had been arrested. (Id. at p. 1004.) In addition, they testified regarding the statistical rates at which arrested drivers in prior cases had produced similarly falsified vehicle documents and claimed they did not know they were driving stolen vehicles. (Id. at pp. 1004-1006.)

The appellate court concluded the experts had offered only improper and prejudicial "profile" testimony, as it relied exclusively on the defendant's similarities to other persons charged with unrelated crimes. (People v. Martinez, supra, 10 Cal.App.4th at pp. 1007-1008.) The court stated:

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